ML12279A012

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Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. Volume 3 (Redacted Version). Page 1934 of 2430 to End
ML12279A012
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 09/30/2012
From:
Southern Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation
References
Download: ML12279A012 (916)


Text

[[:#Wiki_filter:REDACTED VERSION VOLUME 3 Southern Nuclear Operating Company, Inc. Joseph M. Farley Nuclear Plant Docket 50-348 and 50-364 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition SOUTHERNEI COMPANY Transition Report September, 2012

AttachnD Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) C 0 Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-042-SEP-044 VFDR N2B21TR0410:AVAILABLE-TE430:AVALABLE-TE430, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TRO410 (TE430)- RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component power supply may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 80t. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determiled that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-045 VFDR N2B21TR0413:AVAILABLE-TE433:AVAILABLE-TE433, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE430) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component power supply may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-042-SEP-046 VFDR Q2B31 L0001A:ON/OFF:OFF, PRESSURIZER HEATER GROUP 2A DISTRIBUTION PANEL - Q2B31 L0001A - Pressurizer Heater Group 2A Distribution Panel. The Heater is normally in standby, required off to prevent RCS pressure transients. Fire induced damage to power supplies can prevent ability to trip heater, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1934 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-047 VFDR Q2B31 L0001 B:ON/OFF:ON/OFF, PRESSURIZER HEATER GROUP 2B DISTRIBUTION PANEL - Q2B31 L0001 B - Pressurizer Heater Group 2B Distribution Panel. The heater is normally available, required available to control pressure. Fire induced cable damage and power failures result in failure of heater operation, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-048 VFDR Q2B31L0001B:ON/OFF:ON/OFF, PRESSURIZER HEATER GROUP 2B DISTRIBUTION PANEL - Q2B31L0001 B - Pressurizer Heater Group 2B Distribution Panel. The Heater is normally in standby, required off to prevent RCS pressure transients. Fire induced cable damage can prevent ability to trip heater, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-049 VFDR N2B31LO001C:ON:OFF, PRESSURIZER HEATER GROUP 2C DISTRIBUTION PANEL - N2B31L0001C - Pressurizer Heater Group 2C Distribution Panel. The Heater is normally in standby, required off to prevent RCS pressure transients. Fire induced damage to power supplies can prevent ability to trip heater, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1935 of 2430 0 0

Attach Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with.simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-050 VFDR N2B31LO001D:ON:OFF, PRESSURIZER HEATER GROUP 2D DISTRIBUTION PANEL - N2B31L0001D - Pressurizer Heater Group 2D Distribution Panel. The Heater is normally in standby, required off to prevent RCS pressure transients. Fire induced damage to power supplies can prevent ability to trip heater, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-051 VFDR Q2B31V0053:CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF - Q2B31V0053 - Pressurizer Power Operated Relief; N2B31PT0445 - Safety Injection Pressurizer Tank Pressure Transmitter. The valve is normally closed, required to cycle to control RCS pressure. Fire induced damage due to instrument air components, power supplies and transmitter signal prevent the ability to control RCS pressure, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-056 VFDR Q2E21P0002A:ON:ON/OFF, 2A CHARGING PUMP - Q2E21P0002A - 2A Charging Pump; Q2E21P0002B - 2B Charging Pump Q2R41L0001B - 125Vdc Distribution Panel 2B: Q2R43E0001A - Sequencer Bus 2F. The pump is normally in Standby, required off; sequencer normally available, required available, and panel normally energized, required energized. Fire induced cable damage and cascading power supply failures can prevent tripping the pumps, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1936 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-057 VFDR Q2E21 P0002B:ON:ON/OFF-TRAIN A, 2B CHARGING PUMP - Q2E21 P0002A - 2A Charging Pump; Q2E21 P0002B - 2B Charging Pump Q2R41 L0001 B - 125Vdc Distribution Panel 2B; Q2R43EO001A - Sequencer Bus 2F. The pump is normally in Standby, required off; sequencer normally available, required available, and panel normally energized, required energized. Fire induced cable damage and cascading power supply failures can prevent tripping the pumps, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-058 VFDR Q2E21VO016A:CLOSED:CLOSED, HHSI TO RCS COLD LEG ISOLATION - Q2E21VO016A - HHSI to RCS Cold Leg Isolation. The valve is normally closed, required closed to prevent charging pump run out. Fire induced damage to instruments generate a spurious SIAS signal to cause failure of charging pump, and a challenge to the Reactivity Control and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-059 VFDR Q2E21VO016B:CLOSED:CLOSED-TRAIN B, HHSI TO RCS COLD LEG ISOLATION - Q2E21V0016B - HHSI to RCS Cold Leg Isolation. The valve is normally closed, required closed to prevent charging pump run out. Fire induced damage to instruments generate a spurious SIAS signal to cause failure of charging pump, and a challenge to the Reactivity Control and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1937 of 2430 0 0

0 Attachm@C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-060 VFDR Q2E21V0258:CLOSED:OPEN, CHARGING PUMPS TO REGEN HX - Q2E21V0258 - Charging Pumps to Regen HX. The valve is normally open, required to open to maintain RCS inventory. Fire induced spurious SIAS signal generated by instrument failure can preventing ability to provide charging, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-061 VFDR Q2E21V0257:OPEN:OPEN, CHARGING PUMPS TO REGEN HX - Q2E21V0257 - Charging Pumps to Regen HX. The valve is normally open, required to open to maintain RCS inventory. Fire induced damage to instruments generate a spurious SIAS signal to close the valve preventing ability to provide charging, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-062 VFDR Q2E21V0347:MODULATED:MODULATE, CHARGING FLOW CONTROL VALVE - Q2E21V0347 - Charging Flow Control Valve. The valve is normally modulated, required modulated to provide makeup. Fire induced cable damage, instrument air components failure and cascading power supply failures can prevent makeup, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4..1) Farley Run: 08/18/2012 22:11 Page: 1938 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-063 VFDR Q2E21V0376A:OPEN:OPEN, VCT OUTLET ISOLATION - Q2E21V0376A - VCT Outlet Isolation; Q2E21V0376B - VCT Outlet Isolation. The valve is normally open, required open to supply VCT to charging pump. Fire induced damage to instruments generate SIAS or low VCT level to spuriously operate valves to cause failure of charging pump, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-064 VFDR Q2E21V0376B:OPEN:OPEN, VCT OUTLET ISOLATION - Q2E21V0376A - VCT Outlet Isolation; Q2E21V0376B - VCT Outlet Isolation. The valve is normally open, required open to supply VCT to charging pump. Fire induced damage to instruments generate SIAS or low VCT level to spuriously operate valves to cause failure of charging pump, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-065 VFDR N2N21PO001A:ON/STANDBY:OFF, CONDENSATE PUMP 2A - N2N21 P0001A - Condensate Pump 2A; N2N21 P0001B - Condensate Pump 2B; N2N21POO01C - Condensate Pump 2C; Q2N21VO001A - A Steam Generator Main Feed Stop Check Valve MOV3232A, Q2N21VO001B - B Steam Generator Main Feed Stop Check Valve MOV3232B, Q2N21V0001C - C Steam Generator Main Feed Stop Check Valve MOV3232C. The pumps are normally on required off, the valve is normally open, required closed to prevent steam generator overfill. Fire induced cable damage can fail pumps on and fail valve open, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1939 of 2430

Attacht* C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4,2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-066 VFDR N2N21PO001B:ON/STANDBY:OFF, CONDENSATE PUMP 2B - N2N21PO001A - Condensate Pump 2A; N2N21P0001B - Condensate Pump 2B; N2N21POO01C - Condensate Pump 2C; Q2N21VO001A - A Steam Generator Main Feed Stop Check Valve MOV3232A, Q2N21VO001B - B Steam Generator Main Feed Stop Check Valve MOV3232B, Q2N21VO001C - C Steam Generator Main Feed Stop Check Valve MOV3232C. The pumps are normally on required off, the valve is normally open, required closed to prevent steam generator overfill. Fire induced cable damage can fail pumps on and fail valve open, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-067 VFDR N2N21P0001C:ON/STANDBY:OFF, CONDENSATE PUMP 2C - N2N21P0001A - Condensate Pump 2A; N2N21P0001B - Condensate Pump 2B; N2N21P0001C - Condensate Pump 2C; Q2N21VO001A - A Steam Generator Main Feed Stop Check Valve MOV3232A, Q2N21VO001B - B Steam Generator Main Feed Stop Check Valve MOV3232B, Q2N21VO001C - C Steam Generator Main Feed Stop Check Valve MOV3232C. The pumps are normally on required off, the valve is normally open, required closed to prevent steam generator overfill. Fire induced cable damage can fail pumps on and fail valve open, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-068 VFDR Q2B41PO001A:ON:OFF, RCP 2A - Q2B41 P0001A - RCP 2A. The pump is normally on, required off to prevent RCS inventory losses. Fire induced cable damage and control power supply failure may prevent pump trip, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1940 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-069 VFDR Q2B41P0001B:ON:OFF, RCP 2B - Q2B41P0001B - RCP 2B. The pump is normally on, required off to prevent RCS inventory losses. Fire induced cable damage and control power supply failure may prevent pump trip, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-070 VFDR Q2B31V0061:CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF VALVE - Q2B31V0061 - Pressurizer Power Operated Relief. The valve is normally closed, required closed to control pressure. Fire induced cable damage prevent ability to adequately control RCS pressure control, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-071 VFDR Q2P17HV3045:OPEN:CLOSED, CCW FROM RCP THERMAL BARRIER - Q2P17V0082 - CCW to RCP Oil Coolers, Q2P17HV3184 - CCW from RCP Thermal Barrier, Q2P17HV3045 - CCW from RCP Thermal Barrier, Q2P17V0099 - CCW from RCP Oil Cooler. The valves are normally open, required closed either close V0082 or close V0099 and either HV3045 or HV3184 to prevent water hammer of CCW system and potential failure to support all Nuclear Safety Performance Criteria This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1941 of 2430 0

Attachn* Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) C 0 Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-042-SEP-072 VFDR Q2P17HV3184:OPEN:CLOSED, CCW FROM RCP THERMAL BARRIER - Q2P17V0082 - CCW to RCP Oil Coolers, Q2P17HV3184 - CCW from RCP Thermal Barrier, Q2P17HV3045 - CCW from RCP Thermal Barrier, Q2P17V0099 - CCW from RCP Oil Cooler. The valves are normally open, required closed either close V0082 or close V0099 and either HV3045 or HV3184 to prevent water hammer of CCW system and potential failure to support all Nuclear Safety Performance Criteria .This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-042-SEP-073 VFDR Q2P17V0082:OPEN:CLOSED, CCW TO RCP COOLERS - Q2P17V0082 - CCW to RCP Oil Coolers, Q2P17HV3184 - CCW from RCP Thermal Barrier, Q2P17HV3045 - CCW from RCP Thermal Barrier, Q2P17V0099 - CCW from RCP Oil Cooler. The valves are normally open, required closed either close V0082 or close V0099 and either HV3045 or HV3184 to prevent water hammer of CCW system and potential failure to support all Nuclear Safety Performance Criteria This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-042-SEP-074 VFDR Q2P17V0099:OPEN:CLOSED, CCW FROM RCP OIL COOLERS - Q2P17V0082 - CCW to RCP Oil Coolers, Q2P17HV3184 - CCW from RCP Thermal Barrier, Q2P17HV3045 - CCW from RCP Thermal Barrier, 02P17V0099 - CCW from RCP Oil Cooler. The valves are normally open, required closed either close V0082 or close V0099 and either HV3045 or HV3184 to prevent water hammer of CCW system and potential failure to support all Nuclear Safety Performance Criteria This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-042-SEP-075 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1942 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2E1 1P0001A:OFF:ON/OFF, 2A RHR/LHSI PUMP - Q2E1 1P0001A - 2A RHR/LPSI Pump; Q2E1 1P0001 B - 2B RHR/LPSI Pump; Q2R43E0001A - Sequencer Bus 2F. The pump is normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced cable damage, spurious SIAS signal and / or damage to sequencer may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-076 VFDR Q2E1 1 P0001 B:OFF:ON/OFF, 2B RHR/LHSI PUMP - Q2E1 1POO01A - 2A RHR/LPSI Pump; Q2E1 1P0001B - 2B RHR/LPSI Pump; Q2R43E0001A - Sequencer Bus 2F. The pump is normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced cable damage, spurious SIAS signal and / or damage to sequencer may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-077 VFDR N2C55Ni0031A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-31A - N2C55NI0031A - Source Range Count Rate Indicator NI-31A and Q2R21L0001A - 120V Vital AC Instrument Panel 2A; N2C55NI0032A - Source Range Count Rate Indicator NI-32A and Q2R21L0001B - 120V Vital AC Instrument Panel 2B. The indicator is normally available, required available to monitor shutdown margin. Fire induced cable damage and cascading power supply failures prevent the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-042-SEP-078 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1943 of 2430

Attachn Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) C 0 Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR N2C55N10032A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-32A - N2C55NI0031A - Source Range Count Rate Indicator NI-31A and Q2R21LOO01A - 120V Vital AC Instrument Panel 2A; N2C55NI0032A - Source Range Count Rate Indicator NI-32A and Q2R21LOO01B - 120V Vital AC Instrument Panel 2B. The indicator is normally available, required available to monitor shutdown margin. Fire induced cable damage and cascading power supply failures prevent the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-042-SEP-079 VFDR Q2N1 1 PV3371 A:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - Q2N1 1PV3371A - Main Steam Atmos Relief. The valve is normally closed, required to cycle to control steam generator pressure. Fire induced cable damage, instrument air components failure and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-080 VFDR Q2N11PV3371 B:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - Q2N11PV3371B - Main Steam Atmos Relief. The valve is normally closed, required to cycle to control steam generator pressure. Fire induced cable damage, instrument air components failure and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-081 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1944 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N1 1PV3371C:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - Q2N1 1PV3371C - Main Steam Atmos Relief. The valve is normally closed, required to cycle to control steam generator pressure. Fire induced cable damage, instrument air components failure and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-082 VFDR Q2N1 1V0002A:OPEN:CLOSED, 2A SG MSIV - Q2N1 1VO002A - 2A SG MSIV. The valve is normally open, required closed to control steam generator pressure. Fire induced cable damage may fail open valve and prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-083 VFDR Q2N1 1V0002B:OPEN:CLOSED, 2B SG MSIV - Q2N1 1V0002B - 2B SG MSIV. The valve is normally open, required closed to control steam generator pressure. Fire induced cable damage may fail open valve and prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-084 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1945 of 2430

Attachnil C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N1 1V0002C:OPEN:CLOSED, 2C SG MSIV - Q2N1 1VO002C - 2C SG MSIV. The valve is normally open, required closed to control steam generator pressure. Fire induced damage to power supplies may fail open valve and prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Sedtion 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-085 VFDR Q2N12V0001A:CLOSED:CLOSED, TDAFP STEAM SUPPLY ISOLATION VALVE HV3235A - Q2N12V0001A - TDAFP Steam Supply Isolation Valve HV3235A. The valve is normally closed, required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced cable damage and cascading power supply to instruments cabinets generate a spurious signal, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-086 VFDR Q2N12V0001B:CLOSED:CLOSED, TDAFP STEAM SUPPLY ISOLATION VALVE HV3235B - Q2N12V0001B - TDAFP Steam Supply Isolation Valve HV3235B. The valve is normally closed, required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced cable damage and cascading power supply to instruments cabinets generate a spurious signal, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-087 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1946 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N23HV3228A:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2A - Q2N23P0002 - TDAFW Pump: Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced cable damage, instrument air components failures, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-088 VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced cable damage, instrument air components failures, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-089 VFDR Q2N23HV3228B:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2B - Q2N23P0002 - TDAFW Pump; Q2N23HV3228B - TDAFW Supply to Steam Generator 2B. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced cable damage, instrument air components failures, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-090 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1947 of 2430 0

AttachrrW C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N23HV3228C:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2C - Q2N23P0002 - TDAFW Pump: Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced cable damage, instrument air components failures, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-091 VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced cable damage, instrument air components failures, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-092 VFDR Q2N23P0001B:OFF:ON/OFF, 2B MDAFW PUMP - Q2N23P0001B - 2B MDAFW Pump. The pump is normally off, required on to provide AFW to a steam generator. Fire induced cable damage can prevent the ability of pump to deliver flow to steam generator, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-093 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1948 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2B41P0001A:ON:OFF, RCP 2A - Q2B41P0001A - RCP 2A. The pump is normally on, required off to prevent RCS inventory losses. Fire induced cable damage and control power supply failure may prevent pump trip, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-094 VFDR Q2B41P0001 B:ON:OFF, RCP 2B - Q2B41 P0001B - RCP 2B. The pump is normally on, required off to prevent RCS inventory losses. Fire induced cable damage and control power supply failure may prevent pump trip, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-042-SEP-095 VFDR Q2B41P0001C:ON:OFF, RCP 2C - Q2B41 P0001C - RCP 2C. The pump is normally on, required off to prevent RCS inventory losses. Fire induced cable damage to power supply may prevent pump trip, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1949 of 2430 s

0 Attach*S C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-Ul - Aux Building Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 2-S12-U1 Stairwell No. 12 2452-U1 2452 Storage Area 2462-Ul 2462 Nonradioactive Ventilation Equipment Room 2463-U1 2463 Storage Room 2464-U1 2464 Storage Room 2502-U1 2502 Unassigned Area 2506-Ul 2506 Component Cooling Surge Tank Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1950 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-Ul - Aux Building Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1951 of 2430

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0 Attachm*C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-Ul - Aux Building Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/M B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by performance-based approach Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1952 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-Ul - Aux Building Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
  • The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
  • The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1953 of 2430

AttachD*C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-043-Ul - Aux Building Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Detection 2A-1 10 Risk Criteria Required to meet DID criteria. Detection 2A-51 Risk Criteria Required to meet risk criteria. Detection 2A-51 [2452] EEEE/LA Required to support a fire area boundary evaluation. Detection 2A-51 [2452] Risk Criteria Required to meet risk criteria. Water Suppression 2A-52 EEEE/LA Required to support a fire area boundary evaluation. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1954 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-Ul - Aux Building Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area 2-043-U1 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the installed detection system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF Epsilon A LERF Epsilon DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1955 of 2430 0

0 Attach** C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-Ul - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U1-2-043-SEP-001 VFDR QSV49K0001 B:STANDBY:ON, CONTROL ROOM PACKAGE A/C BLOWER UNIT B - QSV49KO001 B - Control Room A/C Blower Unit B. The blower is normally in standby, required on to provide control room HVAC. Fire induced cable damage can disable blower, and a challenge to vital auxiliaries support for primary control station habitability for all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1956 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 2-S12-U2 Stairwell No. 12 2452-U2 2452 Storage Area 2462-U2 2462 Nonradioactive Ventilation Equipment Room 2463-U2 2463 Storage Room 2464-U2 2464 Storage Room 2502-U2 2502 Unassigned Area 2506-U2 2506 Component Cooling Surge Tank Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1957 of 2430

Attachm* C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-043-U2 - Aux Building Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train B charging pump or swing charging pump via Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves. Excess letdown is Paths isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by performance

                                                  -based approach tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves.

4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are performance-based approach shut off. Undesired pressure increase is prevented by performance-based approach deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with performance-based Control approach Train B PORV for pressure reduction and Pressurizer Heater Group B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1958 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train B MDAFW pump supplying Steam Generator 2C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Performance-based approach shutdown margin is rna'nitored. 2. RCS Pressure - RCS pressure is monitored by PZR narrow r~nge Ch 3, PZR non-safety channel, RCS wide range pressure for Loop

1. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch
3. 4. RCS Temperature - Performance-based approach RCS Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure -

Performance-based approach Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train B equipment. 7.2 Vital Auxiliaries - Service Water Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolate 7.3 Vital Auxiliaries - Component Cooling Train B component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by performance-based approach Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1959 of 2430 0

0 Attach*n C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1960 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Detection 2A-110 Risk Criteria Required to meet risk criteria. Detection 2A-110 DID Criteria Required to meet DID criteria. Detection 2A-51 Risk Criteria Required to meet risk criteria. Detection 2A-51 DID Criteria Required to meet DID criteria. Detection 2A-51 [Zone 2452] EEEE/LA Required to support a fire area boundary evaluation. Detection 2A-51 [Zone 2452] Risk Criteria Required to meet risk criteria. Detection 2A-51 [Zone 2452] DID Criteria Required to meet DID criteria. Water Suppression 2A-51 DID Criteria Required to meet DID criteria. Water Suppression 2A-52 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2A-52 DID Criteria Required to meet DID criteria. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Modifications DID Criteria Modification to provide Train B power to the temperature recorder to maintain RCS temperature indication for Loop 2 when Train A power is not available. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1961 of 2430

0 Attach* C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area 2-043-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the modification to provide Train B power to the temperature recorder to maintain RCS temperature indication for Loop 2 when Train A power is not available and the installed detection/suppression systems, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.02E-07 A LERF 1.56E-1 0 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, modification to provide Train B power to the temperature recorder to maintain RCS temperature indication for Loop 2 when Train A power is not available and the installed detection and suppression systems were identified as required for DID. Safety Margin Maintained All analyses and aslessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As sucA, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1962 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-043-IA-001 VFDR Q2B31V0061 :CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF VALVE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. The normally closed PORV valve required to cycle to control RCS pressure transient. Fire induced damage to instrument air components may result in spuriously closing of the valves, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-001 VFDR N2B31LO001C:ON:OFF, PRESSURIZER HEATER GROUP 2C DISTRIBUTION PANEL - The Heater is normally in standby, required off to prevent RCS pressure transients. Fire induced cable damage can prevent ability to trip heater, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-002 VFDR N2B311L0001 D:ON:OFF, PRESSURIZER HEATER GROUP 2D DISTRIBUTION PANEL - The Heater is normally in standby, required off to prevent RCS pressure transients. Fire induced cable damage can prevent ability to trip heater, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-003 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1963 of 2430 0

AttachnoC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR N2B31LO001E:ON:OFF, PRESSURIZER HEATER GROUP 2E DISTRIBUTION PANEL - The Heater is normally in standby, required off to prevent RCS pressure transients. Fire induced cable damage can prevent ability to trip heater, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-004 VFDR N2N1 1 P10475:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A DISCHARGE PRESSURE - The indicator is normally available, required available at least one indicator steam generator pressure is required to provide process monitoring of steam generator pressure. Fire induced cable damage results in failure to monitor the steam generator pressure, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-005 VFDR N2N1 1 P10476:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A DISCHARGE PRESSURE - The indicator is normally available, required available at least one indicator steam generator pressure is required to provide process monitoring of steam generator pressure. Fire induced cable damage results in failure to monitor the steam generator pressure, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-006 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1964 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR N2N1 1P10485:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B DISCHARGE PRESSURE - The indicator is normally available, required available at least one indicator steam generator pressure is required to provide process monitoring of steam generator pressure. Fire induced cable damage results in failure to monitor the steam generator pressure, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-007 VFDR N2N1 1P10486:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B DISCHARGE PRESSURE - The indicator is normally available, required available at least one indicator steam generator pressure is required to provide process monitoring of steam generator pressure. Fire induced cable damage results in failure to monitor the steam generator pressure, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-008 VFDR N2N1 1P10495:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C DISCHARGE PRESSURE - The indicator is normally available, required available at least one indicator steam generator pressure is required to provide process monitoring of steam generator pressure. Fire induced cable damage results in failure to monitor the steam generator pressure, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-009 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1965 of 2430

O AttachmoC O Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR N2N1 1PI0496:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C DISCHARGE PRESSURE - The indicator is normally available, required available at least one indicator steam generator pressure is required to provide process monitoring of steam generator pressure. Fire induced cable damage results in failure to monitor the steam generator pressure, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-01 1 VFDR Q2B41 P0001A:ON:OFF, RCP 2A - The pump is normally on, required off to prevent RCS inventory losses. Fire induced cable damage may prevent pump trip, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-012 VFDR Q2N1 1PV3371A:CLOSED:CLOSED, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required closedjL control steam generator pressure. Fire induced cable damage can spuriously open valve and prevent the ability to control steam generator pressure, and a 6hallenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-013 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1966 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N1 1 PV3371 B:CLOSED:CLOSED, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required closed to control steam generator pressure. Fire induced cable damage can spuriously open valve and prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-014 VFDR Q2N1 1 PV3371C:CLOSED:CLOSED, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required closed to control steam generator pressure. Fire induced cable damage can spuriously open valve and prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-015 VFDR Q2V47MOV3643:OPEN:OPEN, 2A BATTERY ROOM EXHAUST DAMPER - The damper is normally open, required open to support battery room ventilation. Fire induced cable damage may disable electrical support, and a challenge to the HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-043-SEP-016 VFDR QSV49KO001 B:STANDBY:ON, CONTROL ROOM PACKAGE A/C BLOWER UNIT B - The blower is normally in standby, required on to provide control room HVAC. Fire induced cable damage can disable blower, and a challenge to vital auxiliaries support for primary control station habitability for control room HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1967 of 2430 0

Attach C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-043-SEP-017 VFDR N2B21TR0410:AVAILABLE-TE41O:AVAILABLE-TE410, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TRO410 (TE410) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE413) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 1 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-043-SEP-018 VFDR N2B21TR0413:AVAILABLE-TE413:AVAILABLE-TE413, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TR0410 (TE410) - RCS Cold Leg Temperature Recorder TR-410: N2B21TR0413 (TE413) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 1 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provideprocess monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-043-SEP-019 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1968 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR N2B21TR041O:AVAILABLE-TE420:AVAILABLE-TE420, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TRO410 (TE420) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE423) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 2 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-043-SEP-020 VFDR N2B21TR0413:AVAILABLE-TE423:AVAILABLE-TE423, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE420) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE423) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 2 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-043-SEP-021 VFDR N2B21TR0410:AVAILABLE-TE430:AVAILABLE-TE430, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TRO410 (TE430) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1969 of 2430

Attachmn Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) C 0 Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-043-SEP-022 VFDR N2B21TR0413:AVAILABLE-TE433:AVAILABLE-TE433, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE430) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-043-SEP-023 VFDR Q2B31LO001A:ON/OFF:OFF, PRESSURIZER HEATER GROUP 2A DISTRIBUTION PANEL - Q2B31L0001A - Pressurizer Heater Group 2A Distribution Panel, Q2R41L0001B - 125Vdc Distribution Panel 2B. The heater is normally available, required off and panel normally energized, required energized to prevent pressure transient. Fire induced damage due to cascading power failures result in failure prevent heater operation, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Aýfire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-026 VFDR Q2E21POO02A:ON:ON/OFF, 2A CHARGING PUMP - Q2E21P0002A - 2A Charging Pump; Q2E21POO02B - 2B Charging Pump Q2R41L0001B - 125Vdc Distribution Panel 2B. The pump is normally in Standby, required off and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1970 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-043-SEP-027 VFDR Q2E21P0002B:ON:ON/OFF-TRAIN A, 2B CHARGING PUMP - Q2E21P0002A - 2A Charging Pump; Q2E21P0002B - 2B Charging Pump Q2R41L0001B - 125Vdc Distribution Panel 2B. The pump is normally in Standby, required off and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-028 VFDR Q2E21VO016A:CLOSED:CLOSED, HHSI TO RCS COLD LEG ISOLATION - The valve is normally closed, required closed to prevent charging pump run out. Fire induced damage to instruments generate SIAS signal to cause failure of charging pump, and a challenge to the Reactivity Control and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-029 VFDR Q2E21V0257:OPEN:OPEN, CHARGING PUMPS TO REGEN HX - The valve is normally open, required to open to maintain RCS inventory. Fire induced damage to instruments generate a spurious SIAS signal to close the valve preventing ability to provide charging, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-030 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1971 of 2430 0

Attachm*C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-043-U2 - Aux Building I VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2E21V0347:MODULATED:MODULATE, CHARGING FLOW CONTROL VALVE - The valve is normally throttled, required to throttle to maintain RCS inventory. Fire induced damage due to instrument air components and cascading power supply failure prevent ability to maintain reactivity and inventory control, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-031 VFDR Q2E21V0376A:OPEN:OPEN, VCT OUTLET ISOLATION - Q2E21V0376A - VCT Outlet Isolation; Q2E21V0376B - VCT Outlet Isolation. The valves are normally open, required open to supply VCT to charging pump. Fire induced damage to instruments generates a SIAS that can spuriously operate valves to cause failure of charging pump, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-032 VFDR Q2E21V0376B:OPEN:OPEN, VCT OUTLET ISOLATION - Q2E21V0376A - VCT Outlet Isolation; Q2E21V0376B - VCT Outlet Isolation. The valve is normally open, required open to supply VCT to charging pump. Fire induced damage to instruments generates a SIAS that can spuriously operate valves to cause failure of charging pump, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-034 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1972 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2E1 1PO001A:OFF:ON/OFF, 2A RHR/LHSI PUMP - Q2E1 1POO01A - 2A RHR/LPSI Pump; Q2E1 1P0001B - 2B RHR/LPSI Pump. The pumps are normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced damage generates a SIAS signal may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-035 VFDR Q2E1 1P0001 B:OFF:ON/OFF, 2B RHR/LHSI PUMP - Q2E1 1P0001A - 2A RHR/LPSI Pump; Q2E11 P0001 B - 2B RHR/LPSI Pump. The pumps are normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced damage generates a SIAS signal may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-036 VFDR N2C55NI0031A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-31A - N2C55NIO031A - Source Range Count Rate Indicator NI-31A and Q2R21 L0001A - 120V Vital AC Instrument Panel 2A; N2C55NI0032A - Source Range Count Rate Indicator NI-32A and Q2R21 L0001B - 120V Vital AC Instrument Panel 2B. The indicator is normally available, required available to monitor shutdown margin. Fire induced damage due to cascading power supply failures prevent the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-043-SEP-037 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1973 of 2430

0 Attach* C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR N2C55N10032A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-32A - N2C55NI0031A - Source Range Count Rate Indicator NI-31A and Q2R21L0001A - 120V Vital AC Instrument Panel 2A; N2C55NI0032A - Source Range Count Rate Indicator NI-32A and Q2R21L0001B - 120V Vital AC Instrument Panel 2B. The indicator is normally available, required available to monitor shutdown margin. Fire induced damage due to cascading power supply failures prevent the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-043-SEP-038 VFDR Q2N1 1PV3371A:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required modulate to control steam generator pressure. Fire induced cable damage, instrument air components failures and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-039 VFDR Q2N11 PV3371B:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required modulate to control steam generator pressure. Fire induced cable damage, instrument air components failures and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-040 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1974 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N1 1PV3371C:CLOSED:'MODULATE, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required modulate to control steam generator pressure. Fire induced cable damage, instrument air components failures and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-041 VFDR Q2N12V0001A:CLOSED:CLOSED, TDAFP STEAM SUPPLY ISOLATION VALVE HV3235A -The valve is normally closed, required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to cascading power supply to instruments cabinets generate a spurious signal, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-042 VFDR Q2N12V0001B:CLOSED:CLOSED, TDAFP STEAM SUPPLY ISOLATION VALVE HV3235B - The valve is normally closed, required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to cascading power supply to instruments cabinets generate a spurious signal, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-043 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1975 of 2430

0 Attachn* C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N23HV3228A:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2A - Q2N23P0002 - TDAFW Pump; Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-044 VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-045 VFDR Q2N23HV3228B:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2B - Q2N23P0002 - TDAFW Pump; Q2N23HV3228B - TDAFW Supply to Steam Generator 2B. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-046 Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 1976 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-043-U2 - Aux Building VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; Q2N23HV3228B - TDAFW Supply to Steam Generator 2B. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, Oefense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-047 VFDR Q2N23HV3228C:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2C - Q2N23P0002 - TDAFW Pump; Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-043-SEP-048 VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1977 of 2430

0 Attachn*C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2503 2503 Elevator Machine Room No. 4 and Elevator No. 1 Shaft Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1978 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1979 of 2430

S AttachtcC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying.deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                   " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                   " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                   " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1980 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1981 of 2430 0 0

0 Attachm*C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

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Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Detection 2A-110 DID Criteria Required to meet DID criteria. Fire Safety Analysis Data Manager (4. 1 ) Farley Run: 08/18/2012 22:11 Page: 1983 of 2430

AttachmI1C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-054 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the installed detection system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.47E-11 A LERF 3.55E-15 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed detection system was identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1984 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-054-IA-001 VFDR Q2B31V0053:CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2B31V0053 - Pressurizer Power Operated Relief. The valve is normally closed, required modulated to control pressure. Fire induced damage to instrument air components can prevent makeup, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-054-IA-002 VFDR Q2B31V0061 :CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF VALVE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2B31V0061 - Pressurizer Power Operated Relief. The valve is normally closed, required modulated to control pressure. Fire induced damage to instrument air components can prevent makeup, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-054-IA-003 VFDR Q2E21V0347:MODULATED:MODULATE, CHARGING FLOW CONTROL VALVE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2E21V0347 - Charging Flow Control Valve. The valve is normally modulated, required modulated to provide makeup. Fire induced damage to instrument air components can prevent makeup, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1985 of 2430 If

0 Attachm*C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-054-IA-004 VFDR Q2N1 1PV3371 A:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2N1 1PV3371A - Main Steam Atmos Relief. The valve is normally closed, required to cycle to control steam generator pressure. Fire induced damage from instrument air components failure prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable rislý defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-054-IA-005 VFDR Q2N1 1PV3371 B:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2N1 1PV3371B - Main Steam Atmos Relief. The valve is normally closed, required to cycle to control steam generator pressure. Fire induced damage from instrument air components failure prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-054-IA-006 VFDR Q2N1 1PV3371 C:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2N11 PV3371C - Main Steam Atmos Relief. The valve is normally closed, required to cycle to control steam generator pressure. Fire induced damage from instrument air components failure prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1986 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach, - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-CTMT Containment, Unit 2 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1987 of 2430 0 0

0 Attachn C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage

                                                 " Unit 2: Normal letdown is isolated using performance-based approach orifice Paths isolation valves, letdown isolation valve or letdown path containment isolation valve. Excess letdown is performance-based approach isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are performance-based approach isolated using Train A PORVand Train B PORV or the PORV block valves. The RCS to RHR high/low pressure interface is performance-based approach isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve.
                                                 " Unit 1: Normal letdown is isolated using orifice isolation valves, a letdown isolation valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B IRHR outboard isolation valve.

3.3 RCS Inventory Control - RCP Seal Integrity " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by performance-based approach tripping all RCPs, maintaining normal seal injection using Train A/Train B charging pump(s) or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection Fire Safety Analysis Data Manager (4.1)                                                           Farley                                            Run: 08/18/2012 22:11 Page: 1988 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient

                                                 " Unit 2: Undesired depressurization due to inadvertent spray is performance-based approach prevented by ensuring normal and auxiliary spray valves remain closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups.
                                                 " Unit 1: Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups.

4.2 RCS Pressure Control - Positive Pressure " Unit 2: Positive control of RCS pressure is accomplished with performance-Control based approach Train A PORV, Train B PORV or aux spray for pressure reduction and performance-based approach Pressurizer Heater Group B for pressure increase.

                                                 " Unit 1: Positive control of RCS pressure is accomplished with Train A PORV, Train B PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase.

5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A/Train B MDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/lB/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Performance-based approach shutdown margin is monitored. 2. RCS Pressure - Performance-based approach RCS pressure is monitored. 3. Pressurizer Level - Performance-based approach pressurizer level is monitored. 4. RCS Temperature - Performance-based approach RCS Loop 1/Loop 2/Loop 3 temperature is monitored. 5. SG Pressure - Performance-based approach Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Performance-based approach Steam Generator 2A/2B/2C level is monitored.

                                                " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is Fire Safety Analysis Data Manager (4.1)                                                         Farley                                            Run: 08/18/2012 22:11 Page: 1989 of 2430 0                                                                                    S

0, Attachn*C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries Electrical

  • Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
  • Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in Containment. There are no automatic suppression systems in Containment. Equipment is qualified for harsh environment, including water spray and vital equipment is located above the sump submergence level that would be expected during fire suppression activities. Therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1990 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

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Attachrrn C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Detection 2A-22 Risk Criteria Required to meet risk criteria. Detection 2A-22 DID Criteria Required to meet DID criteria. Hose Stations Dry-standpipe system 2-055 Risk Criteria Required to meet risk criteria. Passive RCP Oil Collection System DID Criteria Required to meet DID criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1992 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-055 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the RCP oil collection system and the installed detection and Dry-standpipe suppression systems, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 2.96E-09 A LERF 7.70E-13 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed detection system and RCP oil collection system were identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1993 of 2430 0

Attachno C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-001 VFDR N2B21TR0410:AVAILABLE-TE41O:AVAILABLE-TE410, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TRO410 (TE410) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE413) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 1 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-002 VFDR N2B21TR0410:AVAILABLE-TE420:AVAILABLE-TE420, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TR0410 (TE420) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE423) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 2 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-003 VFDR N2B21TR0410:AVAILABLE-TE430:AVAILABLE-TE430, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TRO410 (TE430) - RCS Cold Leg Temperature Recorder TR-410: N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition'was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1994 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-004 VFDR N2B21TR0413:AVAILABLE-TE413:AVAILABLE-TE413, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE410) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE413) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 1 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-055-SEP-005 VFDR N2B21TR0413:AVAILABLE-TE423:AVAILABLE-TE423, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE420) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE423) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 2 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-055-SEP-006 VFDR N2B21TR0413:AVAILABLE-TE433:AVAILABLE-TE433, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TR0410 (TE430) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TI-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1995 of 2430 0 .0

O Attach* C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table 'B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-007 VFDR N2B31 L10459A:AVAILABLE:AVAILABLE, PRESSURIZER LEVEL INDICATOR - Pressurizer Channel 1, 2, or 3 level indicators provide level indication in the main control room. Fire induced cable damage to instrumentation cables of the indicators could result in inaccurate pressurizer level indication resulting in the potential loss of RCS inventory through the PORVs or relief valves. Failure of the indicators challenges the RCS Inventory Control. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-008 VFDR N2B31 LI0460:AVAILABLE:AVAILABLE, PRESSURIZER LEVEL INDICATOR LI-460 (PROTECTION CHANNEL II) - Pressurizer Channel 1, 2, or 3 level indicators provide level indication in the main control room. Fire induced cable damage to instrumentation cables of the indicators could result in inaccurate pressurizer level indication resulting in the potential loss of RCS inventory through the PORVs or relief valves. Failure of the indicators challenges the RCS Inventory Control. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-009 VFDR N2B31 LI0461 :AVAILABLE:AVAILABLE, PRESSURIZER LEVEL INDICATOR LI-461 (PROTECTION CHANNEL III) - Pressurizer Channel 1, 2, or 3 level indicators provide level indication in the main control room. Fire induced cable damage to instrumentation cables of the indicators could result in inaccurate pressurizer level indication resulting in the potential loss of RCS inventory through the PORVs or relief valves. Failure of the indicators challenges the RCS Inventory Control. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-010 Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 1996 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR N2B31PI0444:AVAILABLE:AVAILABLE, SAFETY INJECTION PRESSURIZER TANK PRESSURE INDICATOR - N2B31PI0444 - Pressurizer Pressure; Q2B31 P10455 - Pressurizer Pressure; Q2B31 P10456 - Pressurizer Pressure; Q2B31 P10457 - Pressurizer Pressure; N2B31 P10445 - Pressurizer Pressure; Q2B21P10402A - RCS Loop C Wide Range Pressure; Q2B21P10403A - RCS Loop A Wide Range Pressure. These indicators are normally available, only one of the indicators is required available to provide process monitoring RCS Inventory and Pressure Control Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the RCS, and a challenge to the process monitoring capability of RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-01 1 VFDR N2B31 P10445:AVAILABLE:AVAILABLE, SAFETY INJECTION PRESSURIZER TANK PRESSURE INDICATOR - N2B31 P10444 - Pressurizer Pressure; Q2B31P10455 - Pressurizer Pressure; Q2B31 P10456 - Pressurizer Pressure; Q2B31P10457 - Pressurizer Pressure; N2B31PI0445 - Pressurizer Pressure; Q2B21P10402A - RCS Loop C Wide Range Pressure; 02B21P10403A - RCS Loop A Wide Range Pressure. These indicators are normally available, only one of the indicators is required available to provide process monitoring RCS Inventory and Pressure Control Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the RCS, and a challenge to the process monitoring capability of RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-012 VFDR N2B31PI0455:AVAILABLE:AVAILABLE, PRESSURIZER PRESSURE INDICATOR PI-455 (PROTECTION CHANNEL I) - N2B31 P10444 - Pressurizer Pressure; Q2B31 P10455 - Pressurizer Pressure; Q2831 P10456 - Pressurizer Pressure; Q2B31 P10457 - Pressurizer Pressure; N2B31 PI0445 - Pressurizer Pressure; Q2B21P10402A - RCS Loop C Wide Range Pressure; Q2B21P10403A - RCS Loop A Wide Range Pressure. These indicators are normally available, only one of the indicators is required available to provide process monitoring RCS Inventory and Pressure Control Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the RCS, and a challenge to the process monitoring capability of RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1997 of 2430

0 Attachm*C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-013 VFDR N2B31PI0456:AVAILABLE:AVAILABLE, PRESSURIZER PRESSURE INDICATOR PI-456 (PROTECTION CHANNEL II)- N2B31PI0444 - Pressurizer Pressure; 02B31PI0455 - Pressurizer Pressure; Q2B31P10456 - Pressurizer Pressure; Q2B31P10457 - Pressurizer Pressure; N2B31P10445 - Pressurizer Pressure; Q2B21P10402A - RCS Loop C Wide Range Pressure; Q2B21PI0403A - RCS Loop A Wide Range Pressure. These indicators are normally available, only one of the indicators is required available to provide process monitoring RCS Inventory and Pressure Control Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the RCS, and a challenge to the process monitoring capability of RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-014 VFDR N2B31P10457:AVAILABLE:AVAILABLE, PRESSURIZER PRESSURE INDICATOR PI-457 (PROTECTION CHANNEL Ill) - N2B31PI0444 - Pressurizer Pressure; Q2B31P10455 - Pressurizer Pressure; Q2B31 P10456 - Pressurizer Pressure; Q2B31P10457 - Pressurizer Pressure; N2B31 P10445 - Pressurizer Pressure; Q2B21 P10402A - RCS Loop C Wide Range Pressure; Q2121 P10403A - RCS Loop A Wide Range Pressure. These indicators are normally available, only one of the indicators is required available to provide process monitoring RCS Inventory and Pressure Control Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the RCS, and a challenge to the process monitoring capability of RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-015 VFDR N2C22LI0474:AVAILABLE:AVAILABLE, STEAM GENERATOR 1A NARROW RANGE LEVEL INDICATOR LI-474 (PROTECTION CHANNEL I) - N2C22Li0476

                               - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0475 - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0474 - Steam Generator 1A Narrow Range Level Indicator; N2N1 1LR0477 (LT477) - Steam Generator 1A Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1998 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-016 VFDR N2C22LI0475:AVAILABLE:AVAILABLE, STEAM GENERATOR 1A NARROW RANGE LEVEL INDICATOR LI-475 (PROTECTION CHANNEL II) - N2C22LI0476 - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0475 - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0474 - Steam Generator 1A Narrow Range Level Indicator; N2N1 lLR0477 (LT477) - Steam Generator 1A Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-017 VFDR N2C22LI0476:AVAILABLE:AVAILABLE, STEAM GENERATOR 1A NARROW RANGE LEVEL INDICATOR LI-476 (PROTECTION CHANNEL III) - N2C22LI0476 - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0475 - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0474 - Steam Generator 1A Narrow Range Level Indicator; N2N11 lLR0477 (LT477) - Steam Generator 1A Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-018 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 1999 of 2430 S

O Attachm@C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR N2C22LI0484:AVAILABLE:AVAILABLE, STEAM GENERATOR 1B NARROW RANGE LEVEL INDICATOR LI-484 (PROTECTION CHANNEL I) - N2C22LI0486

                               - Steam Generator 1B Narrow Range Level Indicator; N2C22LI0485 - Steam Generator 1B Narrow Range Level Indicator; N2C22LI0484 - Steam Generator 1B Narrow Range Level Indicator; N2N1 1LR0477 (LT487) - Steam Generator 1B Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4.

Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-019 VFDR N2C22LI0485:AVAILABLE:AVAILABLE, STEAM GENERATOR 1B NARROW RANGE LEVEL INDICATOR LI-485 (PROTECTION CHANNEL II) - N2C22LI0486 - Steam Generator 1B Narrow Range Level Indicator; N2C22LI0485 - Steam Generator 1B Narrow Range Level Indicator; N2C22L10484 - Steam Generator 1B Narrow Range Level Indicator; N2N11 LR0477 (LT487) - Steam Generator 1B Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-020 VFDR N2C22LI0486:AVAILABLE:AVAILABLE, STEAM GENERATOR 1B NARROW RANGE LEVEL INDICATOR LI-486 (PROTECTION CHANNEL III) - N2C22LI0486 - Steam Generator 1B Narrow Range Level Indicator; N2C22LI0485 - Stdam Generator 1B Narrow Range Level Indicator; N2C22LI0484 - Steam Generator 1B Narrow Range Level Indicator; N2N 11 LR0477 (LT487) - Steam Generator 1B Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2000 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-021 VFDR N2C22LI0495:AVAILABLE:AVAILABLE, STEAM GENERATOR 1C NARROW RANGE LEVEL INDICATOR LI-495 (PROTECTION CHANNEL II)- N2C22LI0496 - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0495 - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0494 - Steam Generator 1C Narrow Range Level Indicator; N2N1 lLR0477 (LT497) - Steam Generator 1C Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-022 VFDR N2C22LI0496:AVAILABLE:AVAILABLE, STEAM GENERATOR 1C NARROW RANGE LEVEL INDICATOR LI-496 (PROTECTION CHANNEL III) - N2C22LI0496 - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0495 - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0494 - Steam Generator 1C Narrow Range Level Indicator; N2N1 1LR0477 (LT497) - Steam Generator 1C Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-023 Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2001 of 2430

0 Attachm*C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR N2C55N10031A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-31A - N2C55NI0031A - Source Range Count Rate Indicator NI-31A and N2C55NI0032A - Source Range Count Rate Indicator NI-32A. The indicator is normally available, required available to monitor shutdown margin. Fire induced cable damage prevents the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-055-SEP-024 VFDR N2C55N10032A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-32A - N2C55NI0031A - Source Range Count Rate Indicator NI-31A and N2C55NI0032A - Source Range Count Rate Indicator NI-32A. The indicator is normally available, required available to monitor shutdown margin. Fire induced cable damage prevents the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-055-SEP-025 VFDR N2N1 1LR0477:AVAILABLE-LT477:AVAILABLE-LT477, 2A, 2B, 2C STEAM GENERATOR WIDE RANGE LEVEL RECORDER - N2C22LI0476 - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0475 - Steam Generator 1A Narrow Range Level Indicator; N2C22LI0474 - Steam Generator 1A Narrow Range Level Indicator; N2N 11 LR0477 (LT477) - Steam Generator 1A Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-026 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2002 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR N2N1 1LR0477:AVAILABLE-LT487:AVAILABLE-LT487, 2A, 2B, 2C STEAM GENERATOR WIDE RANGE LEVEL RECORDER - N2C22LI0486 - Steam Generator 1 B Narrow Range Level Indicator; N2C22LI0485 - Steam Generator 1B Narrow Range Level Indicator; N2C22LI0484 - Steam Generator 1B Narrow Range Level Indicator; N2N11 LR0477 (LT487) - Steam Generator 1B Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-027 VFDR N2N1 1 LR0477:AVAILABLE-LT497:AVAILABLE-LT497, 2A, 2B, 2C STEAM GENERATOR WIDE RANGE LEVEL RECORDER - N2C22LI0496 - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0495 - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0494 - Steam Generator 1C Narrow Range Level Indicator; N2N1 1LR0477 (LT497) - Steam Generator 1C Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-028 VFDR Q2B13HV0001 :CLOSED:CLOSED, REACTOR VESSEL HEAD VENT - Q2B13HV0001 - Reactor Vessel Head Vent and Q2B13HV0002 - Reactor Vessel Head Vent. These valves are normally closed, required closed to prevent loss of RCS inventory. Fire induced cable damage may result in spurious opening of both valves, a diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2003 of 2430 0

Attachn t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table .B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-029 VFDR Q2B13HV0002:CLOSED:CLOSED, REACTOR VESSEL HEAD VENT - Q2B13HV0001 - Reactor Vessel Head Vent and Q2B13HV0002 - Reactor Vessel Head Vent. These valves are normally closed, required closed to prevent loss of RCS inventory. Fire induced cable damage may result in spurious opening of both valves, a diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA.805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-030 VFDR Q2B13HV0003:CLOSED:CLOSED, REACTOR VESSEL HEAD VENT - Q2B13HV0003 - Reactor Vessel Head Vent and Q2B13HV0004 - Reactor Vessel Head Vent. These valves are normally closed, required closed to prevent loss of RCS inventory. Fire induced cable damage may result in spurious opening of both valves, a diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-031 VFDR Q2B13HV0004:CLOSED:CLOSED, REACTOR VESSEL HEAD VENT - Q2B13HV0003 - Reactor Vessel Head Vent and Q2B13HV0004 - Reactor Vessel Head Vent. These valves are normally closed, required closed to prevent loss of RCS inventory. Fire induced cable damage may result in spurious opening of both valves, a diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-032 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2004 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2B21P10402A:AVAILABLE:AVAILABLE, RCS LOOP C WIDE RANGE PRESSURE INDICATOR PI-402A- N2B31PI0444 - Pressurizer Pressure; N2B31P10455 - Pressurizer Pressure; N2B31P10456 - Pressurizer Pressure; N2B31P10457 - Pressurizer Pressure; N2B31P10445 - Pressurizer Pressure; Q2B21P10402A - RCS Loop C Wide Range Pressure; Q2B21P10403A - RCS Loop A Wide Range Pressure. These indicators are normally available, only one of the indicators is required available to provide process monitoring RCS Inventory and Pressure Control Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the RCS, and a challenge to the process monitoring capability of RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-033 VFDR Q2B21 P10403A:AVAILABLE:AVAILABLE, RCS LOOP A WIDE RANGE PRESSURE INDICATOR PI-403A - N2B31 PI0444 - Pressurizer Pressure: N2B31 P10455 - Pressurizer Pressure; N2B31 P10456 - Pressurizer Pressure; N2B31 P10457 - Pressurizer Pressure; N2B31 P10445 - Pressurizer Pressure; Q2B21P10402A - RCS Loop C Wide Range Pressure; Q2B21P10403A - RCS Loop A Wide Range Pressure. These indicators are normally available, only one of the indicators is required available to provide process monitoring RCS Inventory and Pressure Control Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the RCS, and a challenge to the process monitoring capability of RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-034 VFDR Q2131 L0001 B:ON/OFF:ON/OFF, PRESSURIZER HEATER GROUP 2B DISTRIBUTION PANEL - Due to the necessity of maintaining safe and stable conditions for a period of time longer than 24 hours, positive control of the pressurizers is credited; pressurizer heater Group 1B is credited in Fire Area 2-055. Fire induced cable damage to the power cables of individual heater elements could render Pressurizer Heater Group 1B unavailable for temperature control. Failure of Pressurizer Group 1B challenges the RCS Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2005 of 2430 0

SAttach*C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifyingdeterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-035 VFDR Q2B31V0027A:OPEN:OPEN/CLOSED, PORV BLOCK VALVE - Q2B31V0027A - Pressurizer PORV Isolation; Q2B31V0053 - Pressuirizer PORV. The PORV is normally closed and isolation valve normally open, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-036 VFDR Q2B31V0027B:OPEN:OPEN/CLOSED, PORV BLOCK VALVE - Q2B31V0027B - Pressurizer PORV Isolation; Q2B31V0061 - Pressuirizer PORV. The PORV is normally closed and isolation valve normally open, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-037 VFDR Q2B31V0053:CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF - Q2B31V0027A - Pressurizer PORV Isolation; Q2B31V0053 - Pressuirizer PORV. The PORV is normally closed and isolation valve normally open, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-038 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2006 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2B31V0061 :CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF VALVE - Q2B31V0027B - Pressurizer PORV Isolation; Q2B31V0061 - Pressuirizer PORV. The PORV is normally closed and isolation valve normally open, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-042 VFDR Q2B41PO001A:ON:OFF, RCP 2A - Q2B41 P0001A - RCP 2A. This normally running pump is required to be turned off to prevent RCS inventory losses via seal damage and to meet thermo hydraulic analyzed conditions. Fire induced cable damage may result in the inability to trip the RCP from the Control Room, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-043 VFDR Q2B41 P0001B:ON:OFF, RCP 2B - Q2B41P0001B - RCP 2B. This normally running pump is required to be turned off to prevent RCS inventory losses via seal damage and to meet thermo hydraulic analyzed conditions. Fire induced cable damage may result in the inability to trip the RCP from the Control Room, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-044 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2007 of 2430

0 Attachm* C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2B41PO001C:ON:OFF, RCP 2C - Q2B41P0001C - RCP 2C. This normally running pump is required to be turned off to prevent RCS inventory losses via seal damage and to meet thermo hydraulic analyzed conditions. Fire induced cable damage may result in the inability to trip the RCP from the Control Room, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-045 VFDR Q2E1 1V0001A:CLOSED:CLOSED, 2C RCS LOOP TO 2A RHR PUMP - Q2E1 1VO001A - 2C RCS Loop to 2A RHR Pump; Q2E1 1VO016A - 2C RCS Loop to 2A RHR Pump. These valves are the high-low pressure interface. They are normally closed, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-046 VFDR Q2E1 1V0001B:CLOSED:CLOSED, 2A RCS LOOP TO 2B RHR PUMP - Q2E1 1VO001B - 2A RCS Loop to 2B RHR Pump; Q2E1 1VO016B - 2A RCS Loop to 2B RHR Pump. These valves are the high-low pressure interface. They are normally closed, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-047 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2008 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2E1 1V0016A:CLOSED:CLOSED, 2C RCS LOOP TO 2A RHR PUMP - Q2E1 1V0001A - 2C RCS Loop to 2A RHR Pump; Q2E1 1VO016A - 2C RCS Loop to 2A RHR Pump. These valves are the high-low pressure interface. They are normally closed, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-048 VFDR Q2E1 1V0016B:CLOSED:CLOSED, 2A RCS LOOP TO 2B RHR PUMP - Q2E1 1V0001 B - 2A RCS Loop to 2B RHR Pump; Q2E1 1VO016B - 2A RCS Loop to 2B RHR Pump. These valves are the high-low pressure interface. They are normally closed, only one of the valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-049 VFDR Q2E21V0183:CLOSED:CLOSED, EXCESS LETDOWN HX DISCHARGE - Q2E21V0247 - Excess Letdown Isolation; Q2E21V0250 - Excess Letdown Divert; Q2E21V0246 - Excess Letdown Isolation; Q2E21V0183 - Excess Letdown Heat Exchanger discharge. These valves are normally closed, only one of the isolation valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-050 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2009 of 2430

Attach e C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2E21V0243:CLOSED:OPEN, RCS ALTERNATE CHARGING LINE - Q2E21V0243 - RCS Alternate Charging Line and Q2E21V0244 - RCS Normal Charging Line. The normal charging valve is normally open and the alternate charging line is normally closed at least one valve is required open to provide charging for Reactivity and Inventory Control. Fire induced damage to cables may result in spuriously closing of the valves, and a challenge to the Reactivity Control and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-051 VFDR Q2E21V0244:OPEN:MODULATE, RCS NORMAL CHARGING LINE - Q2E21V0243 - RCS Alternate Charging Line and Q2E21V0244 - RCS Normal Charging Line. The normal charging valve is normally open and the alternate charging line is normally closed at least one valve is required open to provide charging for Reactivity and Inventory Control. Fire induced damage to cables may result in spuriously closing of the valves, and a challenge to the Reactivity Control and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-052 VFDR Q2E21V0245:CLOSED:CLOSED, RCS PRESSURIZER AUX SPRAY - Q2E21V0245 - RCS Pressurizer Aux Spray Valve. This normally closed valve required closed to prevent uncontrolled RCS pressure transient. Fire induced cable damage may result in spuriously opening of the valve, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-053 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2010 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2E21V0246:OPEN:CLOSED, EXCESS LETDOWN ISOLATION (UNDER REFUELING CANAL) - Q2E21V0247 - Excess Letdown Isolation; Q2E21V0250 - Excess Letdown Divert; Q2E21V0246 - Excess Letdown Isolation; Q2E21V0183 - Excess Letdown Heat Exchanger discharge. These valves are normally closed, only one of the isolation valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-054 VFDR Q2E21V0247:OPEN:CLOSED, EXCESS LETDOWN ISOLATION (UNDER REFUELING CANAL) - Q2E21V0247 - Excess Letdown Isolation; Q2E21V0250 - Excess Letdown Divert; Q2E21V0246 - Excess Letdown Isolation; Q2E21V0183 - Excess Letdown Heat Exchanger discharge. These valves are normally closed, only one of the isolation valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-055 VFDR Q2E21V0250:TO VCT:TO VCT, EXCESS LETDOWN DIVERT VALVE - Q2E21V0247 - Excess Letdown Isolation; Q2E21V0250 - Excess Letdown Divert; Q2E21V0246 - Excess Letdown Isolation; 02E21V0183 - Excess Letdown Heat Exchanger discharge. These valves are normally closed, only one of the isolation valves is required closed to prevent loss of RCS inventory. Fire induced cable damage to component may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2011 of 2430

S.Attach t i Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-056 VFDR Q2E21V0253A:THROTTLED:MODULATE, LETDOWN ORIFICE ISOLATION 45 GPM - Q2E21HV8149A, Q2E21HV8149B, Q2E21 HV8149C - Letdown Orifice Isolation; Q2E21V0367 - Letdown Line Isolation; Q2E21V0368 - Letdown Line Isolation. These valves are normally open, only one of the Letdown Line isolation valves or all three Letdown Orifice isolation valves are required closed to prevent loss of RCS inventory. Fire induced cable damage to component or instrument cabling/tubing may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-057 VFDR Q2E21V0253B:THROTTLED:MODULATE, LETDOWN ORIFICE ISOLATION 60 GPM - Q2E21HV8149A, Q2E21HV8149B, Q2E21HV8149C - Letdown Orifice Isolation; Q2E21V0367 - Letdown Line Isolation; Q2E21V0368 - Letdown Line Isolation. These valves are normally open, only one of the Letdown Line isolation valves or all three Letdown Orifice isolation valves are required closed to prevent loss of RCS inventory. Fire induced cable damage to component or instrument cabling/tubing may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.'2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-058 VFDR Q2E21V0253C:THROTTLED:MODULATE, LETDOWN ORIFICE ISOLATION 60 GPM - Q2E21HV8149A, Q2E21HV8149B, Q2E21HV8149C - Letdown Orifice Isolation; Q2E21V0367 - Letdown Line Isolation; Q2E21V0368 - Letdown Line Isolation. These valves are normally open, only one of the Letdown Line isolation valves or all three Letdown Orifice isolation valves are required closed io prevent loss of RCS inventory. Fire induced cable damage to component or instrument cabling/tubing may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2012 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-059 VFDR Q2B31V0056:MODULATED:CLOSED, PRESSURIZER SPRAY VALVE Q2B31PCV444C - Q2B41POO01A - RCP 2A: Q2B31V0056 - Pressurizer Spray Valve. This normally running pump is required to be turned off or the normally modulated pressurizer spray valve needs to be closed to prevent uncontrolled RCS pressure transient. Fire induced cable damage may result in the inability to trip the RCP from the Control Room or spray valve cables and instrument cables/tubing can prevent ability to close spray valve, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-060 VFDR Q2B41PO001A:ON:OFF, RCP 2A - Q2B41POO01A - RCP 2A; Q2B31V0056 - Pressurizer Spray Valve. This normally running pump is required to be turned off or the normally modulated pressurizer spray valve needs to be closed to prevent uncontrolled RCS pressure transient. Fire induced cable damage may result in the inability to trip the RCP from the Control Room or spray valve cables and instrument cables/tubing can prevent ability to close spray valve, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-061 VFDR Q2B31 V0060:MODULATED:CLOSED, PRESSURIZER SPRAY VALVE Q2B31PCV444D - Q2B41P0001 B - RCP 2B; Q2B31VO060 - Pressurizer Spray Valve. This normally running pump is required to be turned off or the normally modulated pressurizer spray valve needs to be closed to prevent uncontrolled RCS pressure transient. Fire induced cable damage may result in the inability to trip the RCP from the Control Room or spray valve cables and instrument cables/tubing can prevent ability to close spray valve, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2013 of 2430 0

S.Attachm *c I Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-062 VFDR Q2B41P0001B:ON:OFF, RCP 2B - Q2B41P0001 B - RCP 2B; Q2B31V0060 - Pressurizer Spray Valve. This normally running pump is required to be turned off or the normally modulated pressurizer spray valve needs to be closed to prevent uncontrolled RCS pressure transient. Fire induced cable damage may result in the inability to trip the RCP from the Control Room or spray valve cables and instrument cables/tubing can prevent ability to close spray valve, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-063 VFDR N2C22LI0494:AVAILABLE:AVAILABLE, STEAM GENERATOR 1C NARROW RANGE LEVEL INDICATOR LI-494 (PROTECTION CHANNEL I) - N2C22LI0496

                               - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0495 - Steam Generator 1C Narrow Range Level Indicator; N2C22LI0494 - Steam Generator IC Narrow Range Level Indicator; N2N1 1LR0477 (LT497) - Steam Generator 1C Wide Range Level Recorder. These indicators are normally available, only one of the indicators from the credited Steam Generator is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4.

Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-064 VFDR Q2B31V0027B:OPEN:OPEN/CLOSED, PORV BLOCK VALVE - Q2B31V0027B - Pressurizer PORV Isolation and Q2B31V0061 - Pressurizer PORV; Q2B31V0027A - Pressurizer PORV Isolation and Q2B31V0053 - Pressurizer PORV. The normally open PORV isolation valve and normally closed PORV valves requires isolation valve to remain open and PORV to cycle to control RCS pressure transient. Fire induced cable damage may result in spuriously closing of the valves, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley .Run: 08/18/2012 22:11 Page: 2014 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-065 VFDR Q2B31V0027B:OPEN:OPEN/CLOSED-HSPB, PORV BLOCK VALVE - Q2B31V0027B - Pressurizer PORV Isolation and Q2B31V0061 - Pressurizer PORV; Q2B31V0027A - Pressurizer PORV Isolation and Q2B31V0053 - Pressurizer PORV. The normally open PORV isolation valve and normally closed PORV valves requires isolation valve to remain open and PORV to cycle to control RCS pressure transient. Fire induced cable damage may result in spuriously closing of the valves, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-066 VFDR Q2B31V0053:CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF - Q2B31V0027B - Pressurizer PORV Isolation and Q2B31V0061 - Pressurizer PORV; Q2B31V0027A - Pressurizer PORV Isolation and Q2B31V0053 - Pressurizer PORV. The normally open PORV isolation valve and normally closed PORV valves requires isolation valve to remain open and PORV to cycle to control RCS pressure transient. Fire induced cable damage may result in spuriously closing of the valves, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-067 VFDR 02B31V0061 :CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF VALVE - Q2B31V0027B - Pressurizer PORV Isolation and Q2B31V0061 - Pressurizer PORV; 02B31V0027A - Pressurizer PORV Isolation and Q2B31V0053 - Pressurizer PORV. The normally open PORV isolation valve and normally closed PORV valves requires isolation valve to remain open and PORV to cycle to control RCS pressure transient. Fire induced cable damage may result in spuriously closing of the valves, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2015 of 2430 0

AttachmOc Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-068 VFDR Q2E21V0367:OPEN:OPEN/CLOSED, LETDOWN LINE ISOLATION - Q2E21HV8149A, Q2E21HV8149B, 02E21HV8149C - Letdown Orifice Isolation; Q2E21V0367 - Letdown Line Isolation; Q2E21V0368 - Letdown Line Isolation. These valves are normally open, only one of the Letdown Line isolation valves or all three Letdown Orifice isolation valves are required closed to prevent loss of RCS inventory. Fire induced cable damage to component or instrument cabling/tubing may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4.

                                                                                                                                           .1 Disposition                      This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action.

VFDR ID U2-2-055-SEP-069 VFDR Q2E21V0368:OPEN:OPEN/CLOSED, LETDOWN LINE ISOLATION - Q2E21HV8149A, Q2E21HV8149B, Q2E21HV8149C - Letdown Orifice Isolation; Q2E21V0367 - Letdown Line Isolation; Q2E21V0368 - Letdown Line Isolation. These valves are normally open, only one of the Letdown Line isolation valves or all three Letdown Orifice isolation valves are required closed to prevent loss of RCS inventory. Fire induced cable damage to component or instrument cabling/tubing may result in failure to isolate this diversion of flow from the RCS, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-070 VFDR Q2B31PT0455:AVAILABLE:AVAILABLE, PRESSURIZER PRESS PROT CHANNEL 1 PRESS TRANSMITTER - Although not needed for maintaining safe and stable conditions, a spurious safety injection actuation signal (SIAS) could spuriously start the RHR/LHSI pumps resulting in permanent damage. Fire induced damage to the pressurizer pressure transmitters (located in the fire area) or their associated instrumentation cables could result in a spurious safety injection actuation signal (SIAS) thus damaging the RHR/LHSI pumps and challenging the Decay Heat Removal Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2016 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-071 VFDR Q2B31 PT0456:AVAILABLE:AVAILABLE, PRESSURIZER PRESSURE TRANSMITTER - Although not needed for maintaining safe and stable conditions, a spurious safety injection actuation signal (SIAS) could spuriously start the RHR/LHSI pumps resulting in permanent damage. Fire induced damage to the pressurizer pressure transmitters (located in the fire area) or their associated instrumentation cables could result in a spurious safety injection actuation signal (SIAS) thus damaging the RHR/LHSI pumps and challenging the Decay Heat Removal Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-072 VFDR Q2B31 PT0457:AVAILABLE:AVAILABLE, PRESSURIZER PRESSURE TRANSMITTER - Although not needed for maintaining safe and stable conditions, a spurious safety injection actuation signal (SIAS) could spuriously start the RHR/LHSI pumps resulting in permanent damage. Fire induced damage to the pressurizer pressure transmitters (located in the fire area) or their associated instrumentation cables could result in a spurious safety injection actuation signal (SIAS) thus damaging the RHR/LHSI pumps and challenging the Decay Heat Removal Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-073 VFDR Q2C22LT0474:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. 02C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2017 of 2430

Attachm *C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-074 VFDR Q2C22LT0475:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-075 VFDR Q2C22LT0476:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2018 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-055-SEP-076 VFDR Q2C22LT0484:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-077 VFDR Q2C22LT0485:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; 02C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-078 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2019 of 2430

0 Attachm*C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment a VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0486:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Sleam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue' Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-079 VFDR Q2C22LT0494:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 28 Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-080 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2020 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0495:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Trahsmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter: Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-081 VFDR Q2C22LT0496:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-082 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2021 of 2430

S.AttachmOC 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2N23HV3228A:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 1A - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal., and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-083 VFDR Q2C22LT0474:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter: Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-084 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2022 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0475:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter: Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, .Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-085 VFDR Q2C22LT0476:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-086 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2023 of 2430

Attachtr Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) C 0 Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0484:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-087 VFDR Q2C22LT0485:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-088 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2024 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0486:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-089 VFDR Q2C22LT0494:AVAILABLE:AVAILABLE, STEAM GENERATOR2C LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-090 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2025 of 2430 0

Attachto C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0495:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-091 VFDR Q2C22LT0496:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-092 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2026 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2N23HV3228B:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 1B - Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-093 VFDR Q2C22LT0474:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-094 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2027 of 2430

S Attach*S C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifyingdeterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0475:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-095 VFDR Q2C22LT0476:AVAILABLE:AVAILABLE, STEAM GENERATOR 2A LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-096 Fire Safety Analysis Data Manager (4. 1 ) Farley Run: 08/18/2012 22:11 Page: 2028 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0484:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-097 VFDR Q2C22LT0485:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-098 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2029 of 2430 0

Attach tc C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifyingdeterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0486:AVAILABLE:AVAILABLE, STEAM GENERATOR 2B LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-099 VFDR Q2C22LT0494:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                               - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-100 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2030 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2C22LT0495:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-101 VFDR Q2C22LT0496:AVAILABLE:AVAILABLE, STEAM GENERATOR 2C LEVEL TRANSMITTER - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter; Q2C22LT0476

                                - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria.

Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-055-SEP-102 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2031 of 2430 0

S AttachrisC0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-055 - Containment VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2N23HV3228C:OPEN:OPEN, TDAFW SUPPLY TO STEAM GENERATOR 1C - Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. Q2C22LT0474 - Steam Generator 12A Narrow Range Level Transmitter: Q2C22LT0475 - Steam Generator 2A Narrow Range Level Transmitter: Q2C22LT0476 - Steam Generator 2A Narrow Range Level Transmitter. Q2C22LT0484 - Steam Generator 2B Narrow Range Level Transmitter: Q2C22LT0485 - Steam Generator 2B Narrow Range Level Transmitter; Q2C22LT0486 - Steam Generator 2B Narrow Range Level Transmitter. Q2C22LT0494 - Steam Generator 2C Narrow Range Level Transmitter: 02C22LT0495 - Steam Generator 2C Narrow Range Level Transmitter; Q2C22LT0496 - Steam Generator 2C Narrow Range Level Transmitter. The valve is normally open required throttled. The transmitters are normally available, only two of the transmitters per steam generator are required available to provide control to allow throttling of valve or two of either LT474, LT485 or LT496 for Decay Heat Removal Nuclear Performance Criteria. Fire induced cable/tubing damage to component may result in failure to control the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2032 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U1 - Unit 2 Cable Tunnel - Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 2-075-U1 Unit 2 Cable Tunnel - Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2033 of 2430 0 0

0 Attachr*CC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-Ul - Unit 2 Cable Tunnel - Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room OR Plant shutdown is performed from the Hot Shutdown Panel. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room OR Reactor is manually tripped from the Control Room prior to Control Room evacuation. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train B charging pump or swing charging pump via Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2034 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-Ul - Unit 2 Cable Tunnel - Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored byfource range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level- Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train B component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2035 of 2430

S AttachmOC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-Ul - Unit 2 Cable Tunnel - Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in the area and adjacent areas. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2036 of 2430

Attachment C

                                               .Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3)

Fire Area ID: 2-075-Ul - Unit 2 Cable Tunnel - Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2037 of 2430

AttachrW C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U1 - Unit 2 Cable Tunnel - Train A Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Water Suppression 2D-77 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2D-77 DID Criteria Required to meet DID criteria. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2038 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-Ul - Unit 2 Cable Tunnel - Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area 2-075-U1 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the installed suppression system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. " CDF 1.36E-08 A LERF 4.63E-1 1 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed suppression system was identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2039 of 2430 0

S AttachOC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-Ul - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U1-2-075-SEP-001 VFDR Q1R16B0508:ENERGIZED:ENERGIZED-U1, 600V LOAD CENTER 1R/2R - Q1R16B0508 - 600V Load Center 1R/2R. The load center is normally energized, required energized to support service water. Fire induced cable damage can disable the service water system and a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U1-2-075-SEP-002 VFDR Q1 R17B0509:ENERGIZED:ENERGIZED-U1, MOTOR CONTROL CENTER IS - Q1R17B0509 - Motor Control Center 1S. The MCC is normally energized, required energized to support service water. Fire induced cable damage can disable the service water system and a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U1-2-075-SEP-003 VFDR QIR43EO501A:AVAILABLE:AVAILABLE-SHED, SEQUENCER BUS 1H - Q1R43E0501A - Sequencer Bus 1H. The sequencer is normally available, required available to support service water to pond for HVAC support of Bus 1F. The loss of sequencer can disable service water support for diesel generator, and a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2040 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 2-075-U2 Unit 2 Cable Tunnel - Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2041 of 2430 0 0

Attachm*C 1. 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train B charging pump, or swing charging pump via Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves. Excess letdown is Paths isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by performance-based approach deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with performance-based Control approach Train B PORV for pressure reduction and Pressurizer Heater Group B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using TrTrain B MDAFW pump supplying Steam Generator 2C. Main feed is isolated to prevent uncontrolled cooldown. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2042 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 6 Process Monitoring 1. Shutdown Margin - Performance-based approach shutdown margin is monitored. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 3, PZR non-safety channel, RCS wide range pressure for Loop

1. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch
3. 4. RCS Temperature - Performance-based approach RCS Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure -

Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by diesel generator EDG-2B. 2. 4.16 kV and 600 V power is sup plied by Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train B equipment. 7.2 Vital Auxiliaries - Service Water Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train B component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in the area and adjacent areas. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2043 of 2430

0 AttachtRCC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2044 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Water Suppression 2D-77 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2D-77 DID Criteria Required to meet DID criteria. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Modifications Risk Criteria Modification to replace trip device in panel Q2R42B0001A, breaker LA13. Modifications DID Criteria Modification to provide Train B power to the temperature recorder to maintain RCS temperature indication for Loop 2 when Train A power is not available. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2045 of 2430 0

Attach*f C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area 2-075-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, modification(s), and the installed suppression system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 3.12E-07 A LERF 3.13E-09 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, modification to provide Train B power to the temperature recorder to maintain RCS temperature indication for Loop 2 when Train A power is not available and the installed suppression system were identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained." Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2046 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-075-IA-001 VFDR Q2B31V0061:CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF VALVE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. The normally closed PORV valve required to cycle to control RCS pressure transient. Fire induced damage to instrument air components may result in spuriously closing of the valves, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-075-SEP-001 VFDR N2B21TR0410:AVAILABLE-TE41O:AVAILABLE-TE410, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TRO410 (TE410) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE413) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 1 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-075-SEP-002 VFDR N2B21TR0413:AVAILABLE-TE413:AVAILABLE-TE413, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE410) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE413) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 1 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate forcompliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2047 of 2430

Attachr*C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-075-SEP-003 VFDR N2B21TR041O:AVAILABLE-TE420:AVAILABLE-TE420, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TR0410 (TE420) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE423) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 2 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fireinduced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-075-SEP-004 VFDR N2B21TR0413:AVAILABLE-TE423:AVAILABLE-TE423, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE420) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE423) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 2 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-075-SEP-005 VFDR N2B21TR041O:AVAILABLE-TE430:AVAILABLE-TE430, RCS COLD LEG TEMPERATURE RECORDER TR-410 - N2B21TR0410 (TE430) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2048 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-075-SEP-006 VFDR N2B21TR0413:AVAILABLE-TE433:AVAILABLE-TE433, RCS HOT LEG TEMPERATURE RECORDER TR-413 - N2B21TRO410 (TE430) - RCS Cold Leg Temperature Recorder TR-410; N2B21TR0413 (TE433) - RCS Hot Leg Temperature Indicator TR-413. These RCS Loop 3 indicators are normally available, only one set of the indicators from credited Steam Generator RCS Loop is required available to provide process monitoring of Decay Heat Removal Nuclear Performance Criteria. Fire induced cable damage and cascading power failures result in failure to monitor the decay heat removal, and a challenge to the process monitoring capability of Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that modification(s) are required to meet applicable DID criteria. VFDR ID U2-2-075-SEP-007 VFDR Q2B31LO001A:ON/OFF:OFF, PRESSURIZER HEATER GROUP 2A DISTRIBUTION PANEL - The heater is normally available, required off and panel normally energized, required energized to prevent pressure transient. Fire induced damage to cascading power failures result in failure prevent heater operation, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-010 VFDR Q2E21POO02A:ON:ON/OFF, 2A CHARGING PUMP - Q2E21POO02A - 2A Charging Pump; Q2E21 P0002B - 2B Charging Pump Q2R411L0001 B - 125Vdc Distribution Panel 2B; Q2R43E0001A - Sequencer Bus 2F. The pump is normally in Standby, required off; sequencer normally available, required available; and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2049 of 2430 0

Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-01 1 VFDR Q2E21 P0002B:ON:ON/OFF-TRAIN A, 2B CHARGING PUMP - Q2E21P0002A - 2A Charging Pump: Q2E21P0002B - 2B Charging Pump Q2R41L0001B - 125Vdc Distribution Panel 2B; Q2R43E0001A - Sequencer Bus 2F. The pump is normally in Standby, required off; sequencer normally available, required available; and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-012 VFDR Q2E21V0016A:CLOSED:CLOSED, HHSI TO RCS COLD LEG ISOLATION - The valve is normally closed, required closed to prevent charging pump run out. Fire induced damage to instruments generate SIAS signal to cause failure of charging pump, and a challenge to the Reactivity Control and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-013 VFDR Q2E21V0257:OPEN:OPEN, CHARGING PUMPS TO REGEN HX - The valve is normally open, required to open to maintain RCS inventory. Fire induced spurious SIAS signal generated once the battery is depleted may close the valve preventing ability to provide charging, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2050 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-075-SEP-014 VFDR Q2E21V0347:MODULATED:MODULATE, CHARGING FLOW CONTROL VALVE - The valve is normally throttled, required to throttle to maintain RCS inventory. Fire induced damage due to instrument air components and cascading power supply failure prevent ability to maintain reactivity and inventory control, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-015 VFDR Q2E21V0376A:OPEN:OPEN, VCT OUTLET ISOLATION - Q2E21V0376A - VCT Outlet Isolation; Q2E21V0376B - VCT Outlet Isolation. The valves are normally open, required open to supply VCT to charging pump. Fire induced damage to instruments cabinets power supplies generate SIAS after battery depletion or environmental failure can spuriously operate valves to cause failure of charging pump, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-016 VFDR Q2E21V0376B:OPEN:OPEN, VCT OUTLET ISOLATION - Q2E21V0376A - VCT Outlet Isolation; Q2E21V0376B - VCT Outlet Isolation. The valves are normally open, required open to supply VCT to charging pump. Fire induced damage to instruments cabinets power supplies generate SIAS after battery depletion or environmental failure can spuriously operate valves to cause failure of charging pump, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-017 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2051 of 2430 0

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A f VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2E1 1P0001A:OFF:ON/OFF, 2A RHR/LHSI PUMP - Q2E1 1P0001A - 2A RHR/LPSI Pump; Q2E1 1P0001 B - 2B RHR/LPSI Pump; Q2R43EO001A - Sequencer Bus 2F. The pump is normally off,, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced damage generates a SIAS signal and / or damage to sequencer may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-018 VFDR Q2E1 1P0001B:OFF:ON/OFF, 2B RHR/LHSI PUMP - Q2E1 1P0001A - 2A RHR/LPSI Pump; Q2E1 1POO01B - 2B RHR/LPSI Pump; Q2R43E0001A - Sequencer Bus 2F. The pump is normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced damage generates a SIAS signal and / or damage to sequencer may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-019 VFDR Q2R43E0001A:AVAILABLE:AVAILABLE-SEQ/SHED, SEQUENCER BUS 2F - Q2E1 1PO001A - 2A RHR/LPSI Pump; Q2E1 1POO01B - 2B RHR/LPSI Pump; Q2R43E0001A - Sequencer Bus 2F. The pump is normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced damage generates a SIAS signal and / or damage to sequencer may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-020 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2052 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR N2C55N10031A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-31A - N2C55NI0031A - Source Range Count Rate Indicator NI-31A and Q2R21LOO01A - 120V Vital AC Instrument Panel 2A; N2C55NI0032A - Source Range Count Rate Indicator NI-32A and Q2R21L0001B - 120V Vital AC Instrument Panel 2B. The indicator is normally available, required available to monitor shutdown margin. Fire induced damage due to cascading power supply failures prevent the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based'approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-075-SEP-021 VFDR N2C55NI0032A:AVAILABLE:AVAILABLE, SOURCE RANGE COUNT RATE INDICATOR NI-32A - N2C55NI0031A - Source Range Count Rate Indicator NI-31A and Q2R21L0001A - 120V Vital AC Instrument Panel 2A; N2C55NI0032A - Source Range Count Rate Indicator NI-32A and Q2R21L0001B - 120V Vital AC Instrument Panel 2B. The indicator is normally available, required available to monitor shutdown margin. Fire induced damage due to cascading power supply failures prevent the ability to monitor the achievement of adequate shutdown margin, and a challenge to the Reactivity Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-075-SEP-022 VFDR Q2N 11 PV3371A:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required to cycle to control steam generator pressure. Fire induced damage from instrument air components and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performan'ce Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3.of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-023 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2053 of 2430

Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) s Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N11PV3371B:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required to cycle to control steam generator pressure. Fire induced damage from instrument air components and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-024 VFDR Q2N11PV3371C:CLOSED:CLOSED, MAIN STEAM ATMOS RELIEF - The valve is normally closed, required to cycle to control steam generator pressure. Fire induced damage from instrument air components and cascading power supply failures prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-025 VFDR Q2N12V0001A:CLOSED:CLOSED, TDAFP STEAM SUPPLY ISOLATION VALVE HV3235A - The valve is normally closed, required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to cascading power supply to instruments cabinets generate a spurious signal, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performa . e-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-026 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2054 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N12V0001B:CLOSED:CLOSED, TDAFP STEAM SUPPLY ISOLATION VALVE HV3235B - The valve is normally closed, required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to cascading power supply to instruments cabinets generate a spurious signal, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-027 VFDR Q2N23HV3228A:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2A - Q2N23P0002 - TDAFW Pump; Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-028 VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; Q2N23HV3228A - TDAFW Supply to Steam Generator 2A. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-029 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2055 of 2430 0 S

r tC Attach Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N23HV3228B:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2B - Q2N23P0002 - TDAFW Pump; Q2N23HV3228B - TDAFW Supply to Steam Generator 2B. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was eval.uated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-030 VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; 02N23HV3228B - TDAFW Supply to Steam Generator 2B. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-031 VFDR Q2N23HV3228C:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 2C - Q2N23P0002 - TDAFW Pump; Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-075-SEP-032 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2056 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N23P0002:OFF:ON/OFF, TURBINE DRIVEN AUX FEEDWATER PUMP - Q2N23P0002 - TDAFW Pump; Q2N23HV3228C - TDAFW Supply to Steam Generator 2C. The pump is normally off, required off; valve is normally open required closed to prevent uncontrolled TDAFW supply to steam generator and overfill. Fire induced damage to instrument air components, cascading loss of power to TDAFW UPS and spurious instrument signals on loss of battery may prevent the ability to turn pump off or close valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2057 of 2430

Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-Ul - Unit 2 Cable Tunnel - Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 2-076-U1 Unit 2 Cable Tunnel - Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2058 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-Ul - Unit 2 Cable Tunnel - Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifyingideterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A chargingpump or swing charging pump via Train A power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2059 of 2430 0

0 Attachn tC " Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-Ul - Unit 2 Cable Tunnel - Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop I/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A. 2. 4.16 kV ad 600 V power is supplied by Train A/Train B distribution equipment. 3. 1!25ftDCO power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Performance-based approach Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in the area and adjacent areas. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2060 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-Ul - Unit 2 Cable Tunnel - Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,              ,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2061 of 2430 0

Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-076-Ul - Unit 2 Cable Tunnel - Train B Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Water Suppression 2D-98 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2D-98 DID Criteria Required to meet DID criteria. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2062 of 2430

Attachment C Table C-1 NFPA 805 Ch 4-Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-Ul - Unit 2 Cable Tunnel - Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area 2-076-Ul Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the installed suppression system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.31 E-08 A LERF 4.49E-1 1 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed suppression system was identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2063 of 2430 0

0 Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-076-Ul - Unit 2 Cable Tunnel - Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U1-2-076-SEP-001 VFDR Q1 P1 6V0592:CLOSED:CLOSED, SW TO D/G 2B - 01 P1 6V0592 - SW to D/G 2B. The valve is normally closed, required closed to prevent crosstie of service water system. Fire induced cable damage can cause spurious valve operation and prevent adequate service water support to the diesel generator, and a challenge to the all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2064 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 2-076-U2 Unit 2 Cable Tunnel - Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2065 of 2430 0 0

0 Attach~t C i Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump or swing charging pump via Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves. Excess letdown is Paths isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by performance-based approach deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with performance-based Control approach Train A PORV for pressure reduction and Pressurizer Heater Group A for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2066 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump supplying Steam Generator 2A. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2, RCS wide range pressure for Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2. 4. RCS Temperature - RCS Loop 1/Loop 2 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A equipment. 7.2 Vital Auxiliaries - Service Water Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in the area and adjacent areas. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2067 of 2430

0 Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2068 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Water Suppression 2D-98 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2D-98 DID Criteria Required to meet DID criteria. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Modifications Risk Criteria Modification to replace trip device in panel Q2R42B0001 B, breaker LB07. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012.22:11 Page: 2069 of 2430

S Attachtt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area 2-076-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the specified recovery actions, modification(s), and the installed suppression system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 5.95E-08 A LERF 8.35E-10 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed suppression system was identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2070 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-2-076-IA-001 VFDR Q2B31V0053:CLOSED:OPEN/CLOSED, PRESSURIZER POWER OPERATED RELIEF - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. The valve is normally closed, required to cycle to control RCS pressure. Fire induced damage due to instrument air components prevent the ability to control RCS pressure, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-076-IA-002 VFDR Q2E21V0347:MODULATED:MODULATE, CHARGING FLOW CONTROL VALVE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2E21V0347 - Charging Flow Control Valve. The valve is normally modulated, required modulated to provide makeup. Fire induced damage to instrument air components can prevent makeup, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-IA-003 VFDR Q2N1 1PV3371A:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2N11PV3371A - Main Steam Atmos Relief. The valve is normally closed, required to cycle to control steam generator pressure. Fire induced damage from instrument air components failure prevent the ability to control steam generator pressure, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a .Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4.. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-IA-004 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2071 of 2430 0 0

Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2N23HV3228B:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 1B - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2N23HV3228B - TDAFW Supply to Steam Generator 1B. The valve is normally open, required to close to isolate TDAFW to Steam Generator. Fire induced damage from instrument air component failures will spuriously open valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-IA-005 VFDR Q2N23HV3228C:OPEN:THROTTLED, TDAFW SUPPLY TO STEAM GENERATOR 1C - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Q2N23HV3228C - TDAFW Supply to Steam Generator 1C. The valve is normally open, required to close to isolate TDAFW to Steam Generator. Fire induced damage from instrument air component failures will spuriously open valve, and a challenge to the Decay Heat Removal Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-001 VFDR Q2B31L0001 B:ON/OFF:ON/OFF, PRESSURIZER HEATER GROUP 2B DISTRIBUTION PANEL - Q2B31LOO01B - Pressurizer Heater Group 2B Distribution Panel, Q2R41L0001E - 125Vdc Distribution Panel 2E. The heater is normally available, required off and panel normally energized, required energized to prevent pressure transient. Fire induced damage due to cascading power failures result in failure prevent heater operation, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-002 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2072 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2R41L0001E:ENERGIZED:ENERGIZED, 125V DC DISTRIBUTION PANEL 2E - Q2B31L0001B - Pressurizer Heater Group 2B Distribution Panel, Q2R41 L0001 E - 125Vdc Distribution Panel 2E. The heater is normally available, required off and panel normally energized, required energized to prevent pressure transient. Fire induced damage due to cascading power failures result in failure prevent heater operation, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-003 VFDR N2B31PT0445:AVAILABLE:AVAILABLE, SAFETY INJECTION PRESSURIZER TANK PRESSURE TRANSMITTER - Q2B31V0053 - Pressurizer Power Operated Relief; N2B31 PT0445 - Safety Injection Pressurizer Tank Pressure Transmitter. The valve is normally closed, required to cycle to control RCS pressure. Fire induced damage due to instrument air components and transmitter signal power prevent the ability to control RCS pressure, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-006 VFDR Q2E21POO02B:ON:ON/OFF-TRAIN B, 2B CHARGING PUMP - Q2E21P0002A - 2A Charging Pump; Q1E21P0002B - 2B Charging Pump Q2R41 L0001 B - 125Vdc Distribution Panel 2B; Q2R43E0001A - Sequencer Bus 2F. The pump is normally in Standby, required off, required off; sequencer normally available, required available, and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-007 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2073 of 2430 4.' 0

0 Attach&t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2E21P0002C:ON:ON/OFF, 2C CHARGING PUMP - Q2E21P0002A - 2A Charging Pump; Q1 E21P0002B - 2B Charging Pump Q2R41L0001B - 125Vdc Distribution Panel 2B; Q2R43E0001A - Sequencer Bus 2F. The pump is normally in Standby, required off, required off; sequencer normally available, required available, and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-008 VFDR Q2R41L0001B:ENERGIZED:ENERGIZED, 125V DC DISTRIBUTION PANEL 2B - Q2E21P0002A - 2A Charging Pump; Q1 E21P0002B - 2B Charging Pump Q2R41LO001B - 125Vdc Distribution Panel 2B; Q2R43EO001A - Sequencer Bus 2F. The pump is normally in Standby, required off, required off; sequencer normally available, required available, and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-009 VFDR Q2R43E0001B:AVAILABLE:AVAILABLE-SEQ/SHED, SEQUENCER BUS 2G - Q2E21 P0002A - 2A Charging Pump; Q1 E21 P0002B - 2B Charging Pump Q2R41LOO01B - 125Vdc Distribution Panel 2B; Q2R43EO001A - Sequencer Bus 2F. The pump is normally in Standby, required off, required off; sequencer normally available, required available, and panel normally energized, required energized to turn off pump to prevent overcharging, and a challenge to the RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-010 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2074 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2E21V0258:OPEN:OPEN, CHARGING PUMPS TO REGEN HX - Q2E21V0258 - Charging Pumps to Regen HX. The valve is normally open, required to open to maintain RCS inventory. Fire induced spurious SIAS signal generated once the battery is depleted may close the valve preventing ability to provide charging, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-01 1 VFDR Q2E21V0257:OPEN:OPEN, CHARGING PUMPS TO REGEN HX - Q2E21V0257 - Charging Pumps to Regen HX. The valve is normally open, required to open to maintain RCS inventory. Fire induced spurious SIAS signal generated once the battery is depleted may close the valve preventing ability to provide charging, and a challenge to the Reactivity and RCS Inventory and Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-012 VFDR Q2E1 1 P0001A:OFF:ON/OFF, 2A RHR/LHSI PUMP - Q2E1 1POO01A - 2A RHR/LPSI Pump; Q2E1 1 P0001B - 2B RHR/LPSI Pump; Q2R43EO001A - Sequencer Bus 2F. The pump is normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced damage generates a SIAS signal and / or damage to sequencer may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-076-SEP-013 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2075 of 2430 0

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2E1 1P0001B:OFF:ON/OFF, 2B RHR/LHSI PUMP - Q2E1 1POO01A - 2A RHR/LPSI Pump; Q2E1 1POO01B - 2B RHR/LPSI Pump; Q2R43EO001A - Sequencer Bus 2F. The pump is normally off, required off to prevent pump damage prior to transitioning to a NPO mode shutdown. Fire induced damage generates a SIAS signal and / or damage to sequencer may spuriously start pump, and a challenge to the RCS Inventory and Pressure Control and Decay Heat Removal NPO Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2076 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-077 - Condensate Storage Tank Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-CST Condensate Storage Tank Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2077 of 2430

0 Attachist C 1 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-077 - Condensate Storage Tank Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated. using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2078 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-077 - Condensate Storage Tank Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2079 of 2430 0

0 Attachrt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-077 - Condensate Storage Tank Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2080 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-077 - Condensate Storage Tank Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
  • The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2081 of 2430 0 0

9 Attachet C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-077 - Condensate Storage Tank Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2082 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-078 - Reactor Makeup Storage Tank Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-RWMT Reactor Makeup Storage Tank Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2083 of 2430

0 ' Attachet C 0 Thble C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-078 - Reactor Makeup Storage Tank Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2084 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-078 - Reactor Makeup Storage Tank Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

  • Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                   " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                   " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/M B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                   " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2085 of 2430 0

S Attacht C W Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-078 - Reactor Makeup Storage Tank Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2086 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-078 - Reactor Makeup Storage Tank Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2087 of 2430

AttachCC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-078 - Reactor Makeup Storage Tank Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2088 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-079 - Refueling Water Storage Tank Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire.Zone ID Description 2-RWST Refueling Water Storage Tank Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2089 of 2430 S

0 Attachet C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-079 - Refueling Water Storage Tank Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are

                                                  .secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2090 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-079 - Refueling Water Storage Tank Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                    " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                    " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator lA/1 B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                    " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2091 of 2430

0 Attachl tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-079 - Refueling Water Storage Tank Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2092 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3-) Fire Area ID: 2-079 - Refueling Water Storage Tank Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
  • The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2093 of 2430 0 0

0 Attachre C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-079 - Refueling Water Storage Tank Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-079 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. " CDF 2.69E-08 " LERF 2.74E-1 1 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2094 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-079 - Refueling Water Storage Tank VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-079-SEP-001 VFDR N2F16LI4075A:AVAILABLE:AVAILABLE, RWST LEVEL INDICATOR LI-4075A - RWST indication is required in order to monitor the inventory level in the RWST, as the RWST is the credited suction source for RCS Makeup. Fire induced circuit failure to the RWST level instrumentation N2F16LI4075A and N2F16LI4076B could render the instrumentation unavailable and/or result in erroneous indication. This failure challenges the RCS Inventory Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2095 of 2430

0 Attachr*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-080A Main Transformer No. 3 2-080B Main Transformer No. 2 2-080C Main Transformer No. 1 2-080D Main Transformer (Spare) 2-080E Unit Aux Transformer (Spare Cubicle) 2-080F Unit Aux Transformer 28 2-080G Startup Aux Transformer No. 28 2-080H Startup Aux Transformer No. 2A 2-080K Low Voltage Switchyard - General Area, Unit 2 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2096 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train 8 PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2097 of 2430 0

AttachAt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table 'B-3) Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal - Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                  - Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring

  • Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.
  • Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1 B/1C pressure is monitored.- 6. SG Level - Steam Generator lA/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical

  • Unit 2: 1. Electrical power is supplied by diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
  • Unit 1: 1. Electrical power is supplied by diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4. 1) Farley Fr Run: 08/18/2012 22:11 Page: 2098 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. Each outdoor deluge system provides local protection for individual transformers, and are designed (using curbs, etc.) so water will remain in the vicinity of the affected equipment. Therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2099 of 2430

                                                                                                        .0

SAttach*eC 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revisic, 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

  • The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2100 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Water Suppression 2TR-64 [2-080A, 2-080D] EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2TR-65 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2TR-66 [2-080B,2-080C] EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2TR-67 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2TR-69 EEEE/LA Required to support a fire area boundary evaluation. Passive Combustibles and flammable liquid EEEE/LA Combustible controls are required to support a fire area boundary evaluation. control Passive Combustibles and flammable liquid EEEE/LA Required to support a fire area boundary evaluation. control Passive Curbs EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2101 of 2430

0 Attach~t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2102 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-081 Turbine Building Battery Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 S01 Page: 2103 of 2430 0

S Attach* C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by performance

                                                  -based approach tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers.

RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are performance-based approach shut off.Undesired pressure increase is prevented by performance-based approach deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2104 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                   " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                   " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical

  • Unit 2:1. Electrical power is supplied by diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2105 of 2430

Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2106 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

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Tal CAttache C 0 Table C-I NFPA 805 Oh 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Detection 2T-4 Risk Criteria Required to meet risk criteria. Detection 2T-4 DID Criteria Required to meet DID criteria. Modifications Risk Criteria Modification to provide fuse or other electrical isolation device at the DC shunt connection point. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2108 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-081 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the modification to provide fuse or other electrical isolation device at the DC shunt connection point, and the installed detection system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 6.79E-1 1 A LERF 1.34E-14 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed detection system was identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2109 of 2430 0

0 Attachot C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-081-SEP-001 VFDR N2B31LO001C:ON:OFF, PRESSURIZER HEATER GROUP 2C DISTRIBUTION PANEL - In order to prevent uncontrolled RCS pressurization the Pressurizer Heaters must be tripped. A loss of control power to 125VDC Distribution panel 2G could prevent remote tripping of Pressurizer Group 2C. Panel 2G fails due to fire induced circuit failure to Bus 2K(N2R41 L0502) and Battery 2D (N2R42B0505B) A failure to prevent RCS Pressure transients challenges the RCS Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-081-SEP-002 VFDR N2B31 L0001 D:ON:OFF, PRESSURIZER HEATER GROUP 2D DISTRIBUTION PANEL - In order to prevent uncontrolled RCS pressurization the Pressurizer Heaters must be tripped. A loss of control power to 125V DC Distribution panel 2G. Panel 2G fails due to fire induced circuit failure to Bus 2K(N2R41 L0502) and Battery 2D (N2R42B0505B). A failure to prevent RCS Pressure transients challenges the RCS Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-081-SEP-003 VFDR Q2B41P0001A:ON:OFF, RCP 2A - In order to support the natural circulation cool down process, the Reactor Coolant Pumps must be tripped. A loss of control power to 125V DC Distribution panel 2G, due to fire induced circuit failure to Bus 2K (N2R41 L0502) and Battery 2D (N2R42B0505B) would prevent remote tripping of Reactor Coolant Pump 2A. This failure challenges the RCS Inventory Control/Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-081-SEP-004 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2110 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-081 - Turbine Building Battery Room VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2B41P0001B:ON:OFF, RCP 2B - In order to support the natural circulation cool down process, the Reactor Coolant Pumps must be tripped. A loss of control power to 125V DC Distribution panel 2H, due to fire induced circuit failure to Bus 2J(N1R41 L0501) and Battery 2C (N2R42B0505A) would prevent remote tripping of Reactor Coolant Pump 2B. This failure challenges the RCS Inventory Control/Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-081-SEP-005 VFDR Q2B41P0001C:ON:OFF, RCP 2C - In order to support the natural circulation cool down process, the Reactor Coolant Pumps must be tripped. A loss of control power to 125V DC Distribution panel 2G, due to fire induced circuit failure to Bus 2K (N1 R41 L0502) and Battery 2D (N1 R42B0505B) would prevent remote tripping of Reactor Coolant Pump 2C. This failure challenges the RCS Inventory Control/Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2111 of 2430

0 Attachet C O Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-089 - Lube Oil & Combustible Storage Room Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire ZonelD Description 2150 2150 Lube Oil Storage/Combustible Storage Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2112 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-089 - Lube Oil & Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2113 of 2430 SI

0 Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-089 - Lube Oil & Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                    " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                    " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                    " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical

                                                    " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
                                                    " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 6001V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2114 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-089 - Lube Oil & Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in the area and adjacent areas. Drainage capacity in the general Turbine Building area exceeds expected fire suppression flows. Local hazards protected by sprinkler or water spray systems have sufficient curbing and discharage of manual suppression water in adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2115 of 2430

0 AAttachtc C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-089 - Lube Oil & Combustible Storage Room Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:11 Page: 2116 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-089 - Lube Oil & Combustible Storage Room Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2117 of 2430 S

0 Attachnot C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-090 - Aux Building Combustible Storage & Filter Unit Room Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2107 2107 Combustible Storage/Filter Unit Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2118 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-090 - Aux Building Combustible Storage & Filter Unit Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2119 of 2430 0 0

Attachat C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 TableB-3) 0 Fire Area ID: 2-090 - Aux Building Combustible Storage & Filter Unit Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                   " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring

                                                   " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.
                                                   " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide            I range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level- Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                   " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2120 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-090 - Aux Building Combustible Storage & Filter Unit Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2121 of 2430 0 0

0 Attachot C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-090 - Aux Building Combustible Storage & Filter Unit Room Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and-2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2122 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-090 - Aux Building Combustible Storage & Filter Unit Room Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2123 of 2430 0 0 0

0 Attache*C 4 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-092 - Drumming Station & Storage & Combustible Storage Room Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2420 2420 Drum Storage/Combustible Storage Room 2421 2421 Drumming Station/Combustible Storage Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2124 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-092 - Drumming Station & Storage & Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2125 of 2430

10 ~Attach~tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-092 - Drumming Station & Storage & Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/lC pressure is monitored. 6. SG Level - Steam Generator 1A/1 B/lC level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2126 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-092 - Drumming Station & Storage & Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2127 of 2430 0 S

0 Attachet C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-092 - Drumming Station & Storage & Combustible Storage Room Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                               " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2128 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-092 - Drumming Station & Storage & Combustible Storage Room Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DIDMaintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2129 of 2430 0

                                                                                                ,0

0 Attachn* C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-094 - Aux Building Combustible Storage Room Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2167 2167 Combustible Storage Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2130 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-094 - Aux Building Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2131 of 2430

0 ~Attache C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-094 - Aux Building Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                   " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3: 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                   " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/M B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                   " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2132 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-094 - Aux Building Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is profected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2133 of 2430 0

0 Attachtt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-094 - Aux Building Combustible Storage Room Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                               " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2134 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-094 - Aux Building Combustible Storage Room Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2135 of 2430

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-096 - Aux Building Combustible Storage Room Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2179 2179 Combustible Storage Room Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2136 of 2430

Attachment C I Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-096 - Aux Building Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2137 of 2430

0 Attach*t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-096 - Aux Building Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                   " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                   " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring

                                                   " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.
                                                   " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical

                                                   " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
                                                   " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2138 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-096 - Aux Building Combustible Storage Room Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2139 of 2430

0 Attachtt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-096 - Aux Building Combustible Storage Room Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                               " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                               " The construction of the boundary and the potential issue with the element in question was described,
                               " The fire hazards and fire protection features on both sides of the barrier were described,
                               " Elements with construction features equal to 3-hr boundaries were credited as such,
                               " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2140 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-096 - Aux Building Combustible Storage Room Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Detection 2A-101 EEEE/LA Required to support a fire area boundary evaluation. Water Suppression 2A-101A EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2141 of 2430 0

0 Attach~t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-096 - Aux Building Combustible Storage Room Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2142 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-097 - Filter Hatch Room & Combustible Storage Area Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2404 2404 Filter Hatch Room/Combustible Storage Area Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2143 of 2430 0 0.

0 Attachne C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-097 - Filter Hatch Room & Combustible Storage Area Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2144 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-097 - Filter Hatch Room & Combustible Storage Area Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                    " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                    " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1 B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                    " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2145 of 2430

O Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-097 - Filter Hatch Room & Combustible Storage Area Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2146 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-097 - Filter Hatch Room & Combustible Storage Area Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

  • The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2147 of 2430

O Attache C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-097 - Filter Hatch Room & Combustible Storage Area Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2148 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-098 - Caskwash Storage & Combustible Storage Area Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2447 2447 Caskwash Storage Area Combustible Storage Area Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2149 of 2430

0 Attach&t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-098 - Caskwash Storage & Combustible Storage Area Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump, or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2150 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-098 - Caskwash Storage & Combustible Storage Area Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                  " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressurefor Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored byCR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Lo6ýi 3.temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shut'down Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/lC pressure is monitored. 6. SG Level - Steam Generator 1A/1B/lC level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 ,*ACpower is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2151 of 2430

0 ~~Attachet C1 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-098 - Caskwash Storage & Combustible Storage Area Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in adjacent areas. Essential equipment is protected from damage due to flooding from operation of the fire suppression system by drains and curbs and/or by mounting essential equipment on pedestals or supports. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2152 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-098 - Caskwash Storage & Combustible Storage Area Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2153 of 2430

Attach&t C I Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-098 - Caskwash Storage & Combustible Storage Area Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. ACDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2154 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-DU-ABVB-A Aux Building to Valve Box Ductbanks, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2155 of 2430

0 Attachat C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power.

                                                 " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup

                                                 " Unit 2: RCS inventory is controlled using Train B charging pump or swing charging pump via Train B power aligned to the RWST.
                                                 " Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal charging using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2156 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

  • Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/lC. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/lC pressure is monitored. 6. SG Level - Steam Generator 1A/1B/lC level is monitored.

7.1 Vital Auxiliaries Electrical

  • Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG-2B.. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
                                                " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1 B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2157 of 2430

0 ~Attach&t C0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water

  • Unit 2: Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
  • Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train B component cooling water is provided with non-essential loads isolated.
  • Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated.

7.4 Vital Auxiliaries HVAC

  • Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.
  • Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2158 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2159 of 2430

Attachit C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2160 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-DU-ABVB-A Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 5.43E-1 1 A LERF 8.77E-14 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2161 of 2430 0

0 Attachft C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-DU-ABVB-A-HVAC-001 VFDR Q2R42BO001A:ENERGIZED:ENERGIZED-BC2A, 125V DC BUS 2A - This component, 125V DC Bus 2A (Train A, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-DU-ABVB-A-HVAC-002 VFDR Q2E21 P0002A:ON:ON/OFF, 2A CHARGING PUMP - This component, Charging Pump 2A, requires HVAC support to remain functional. In order to maintain RCS Inventory, the CVCS system is used to inject borated water into the RCS System. The Charging Pumps supply this inventory of borated water. Charging Pump 1A remains free from fire damage, however a loss of pump cooling due to a loss of Train A Service Water could occur. This failure challenges the RCS Inventory Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-DU-ABVB-A-HVAC-003 VFDR Q2R15A0006:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2F - This component, Switchgear 2F, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-DU-ABVB-A-HVAC-004 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2162 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2R1 7B0001 :ENERGIZED:ENERGIZED, MOTOR CONTROL CENTER 2A - This component, MCC 2A, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-DU-ABVB-A-HVAC-005 VFDR Q2R42E0002A:AVAILABLE:AVAILABLE, 125V BATTERY 2A - This component, Battery 2A, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2163 of 2430 0

Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-DU-ABVB-B Aux Building to Valve Box Ductbanks, Train B Fire Safety Analysis Data Ma nager (4.1)MR Farley Run: 08/18/2012 8 2122:11 Page: 2164 of 2430 4

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power.

                                                 " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup " Unit 2: RCS inventory is controlled using Train A chargingpump or swing charging pump via Train A power aligned to the RWST.

  • Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2165 of 2430 0

0 AttachOt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal

                                               " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                               " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                               " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level- Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                               " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2166 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water

  • Unit 2: Performance-based approach Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
  • Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train A component cooling water is provided with non-essential loads isolated.

9 Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC

  • Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.
                                                       - Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:11 Page: 2167 of 2430 0

0 Attach&t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

.Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2168 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2169 of 2430 0

0 Attachat C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-DU-ABVB-B Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.96E-08 A LERF 6.87E-1 1 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2170 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-DU-ABVB-B-HVAC-001 VFDR Q2R42EO001B:ENERGIZED:ENERGIZED, BATTERY CHARGER 2B - This component, Battery Charger 2B, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-DU-ABVB-B-HVAC-002 VFDR Q2R15A0007:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2G - This component, Switchgear 2G, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-DU-ABVB-B-HVAC-003 VFDR Q2R17B0002:ENERGIZED:ENERGIZED, MOTOR CONTROL CENTER 2B - This component, MCC 2B, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-DU-ABVB-B-HVAC-004 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2171 of 2430

0 Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2R42E0002B:AVAILABLE:AVAILABLE, 125V BATTERY 2B - This component, Battery 2B, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-DU-ABVB-B-SEP-001 VFDR Q2P16V0539:CLOSED:OPEN, SW RECIRC TO POND TRAIN A - The pond is the credited source of recirculation for Service Water. It is therefore desired, that valve Q2P1 6V0539 (SW Emergence Recirculation to Pond) open in order to establish a recirculation lineup. Fire induced control circuit damage could render to component inoperable from the control and/or result in spurious operation. Failure to establish recirculation to the pond challenges service water support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-DU-ABVB-B-SEP-002 VFDR Q2P16V0546:OPEN:OPEN/CLOSED, TRAIN A SW DISCHARGE TO RIVER - The pond is the credited source of recirculation for Service Water. The River supply is not credited, and thus, must be isolated. However, before the Pond lineup is established, the SW Discharge Valve (Q2P16V0546) must remain open. It is then desired that the valve close in order to maintain an adequate pond recirculation lineup. Fire induced damage to the control circuit of this valve may result in a loss of control room ability to operate the valve and/or spurious operation. This failure prevents the establishment of Service water discharge to the pond, and poses a challenge to service water support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2172 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 2, Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-DU-DGRWIS-A Diesel Building to RWIS Ductbank, Unit 2, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2173 of 2430 0

Attachit C 10 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 2, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2174 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 2, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                  " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/M B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2175 of 2430 0 S

0 Attach&t C I Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 2, Train A. Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2176 of 2430

Attachment C

                                               '.Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3)

Fire Area ID: 2-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 2, Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2177 of 2430 S

Attach&t C o Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 2, Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2178 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 2, Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-DU-DGRWIS-B Diesel Building to RWIS Ductbank, Unit 2, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2179 of 2430 0

0 Attachit C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 2, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2180 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 2, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1 B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1 B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2181 of 2430

9 ~Attach&t C1 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 2, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2182 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 2, Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2183 of 2430 0 0

0 Attach~tCC : Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 2, Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. t.. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2184 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-DU-DGSWIS-A Diesel Building to SWIS Ductbank, Unit 2, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2185 of 2430 Is 0

SAttachJt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train B charging pump or swing charging pump via Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power,. and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation

                                                *valve.

4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2186 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C.
                                                    .Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2187 of 2430

0 1 Attachat C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC

  • Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.
                                                       - Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2188 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2189 of 2430 0

0 Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2190 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-DU-DGSWIS-A Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.16E-10 A LERF 2.44E-13 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2191 of 2430

0 Attachat C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-DU-DGSWIS-A-HVAC-001 VFDR Q2R42BO001A:ENERGIZED:ENERGIZED-BC2A, 125V DC BUS 2A - This component, 125V DC Bus 2A, requires HVAC support to remain functional. Failure to provide Electrical support to this component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-DU-DGSWIS-A-HVAC-002 VFDR Q2R15A0006:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2F - This component, Switchgear 2F, requires HVAC support to remain functional. Failure to provide HVAC support to this Electrical Component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-DU-DGSWIS-A-HVAC-003 VFDR Q2R17B0001:ENERGIZED:ENERGIZED, MOTOR CONTROL CENTER 2A - This component, MCC A, requires HVAC support to remain functional. Failure to provide HVAC support to this Electrical Component challenges HVAC support Vital Auxiliaries Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2192 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-DU-DGSWIS-B Diesel Building to SWIS Ductbank, Unit 2, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2193 of 2430 0 0

Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump or swing charging pump via Train A power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2194 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C.

Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

  • Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2195 of 2430

0 Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC

  • Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.
  • Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and raintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of'manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2196 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2197 of 2430 0

0 Attachst C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2198 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-DU-DGSWIS-B Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.26E-10 A LERF 2.92E-1 3 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2199 of 2430 0

Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-DU-DGSWIS-B-HVAC-001 VFDR Q2R42B0001B:ENERGIZED:ENERGIZED-BC2B, 125V DC BUS 2B - This component, 125V DC Bus 2B (Train B Battery Room Charger), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-DU-DGSWIS-B-HVAC-002 VFDR Q2R15A0007:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2G - This component, Switchgear 2G (600V Load Center E Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-DU-DGSWIS-B-HVAC-003 VFDR Q2R42E0002B:AVAILABLE:AVAILABLE, 125V BATTERY 2B - This component, 125V DC Battery 2B (Train B Battery Room Exhaust Fan), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2200 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-EMBED-AB - Aux Building Embedded Conduit Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-EMBED-AB Embedded Conduit, Auxiliary Building, Unit 2 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2201 of 2430 0

0 Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table'B-3) Fire Area ID: 2-EMBED-AB - Aux Building Embedded Conduit Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2202 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-EMBED-AB - Aux Building Embedded Conduit Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1iB/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1iB/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2203 of 2430

Attachst C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-EMBED-AB - Aux Building Embedded Conduit Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained in this area due to embedded conduits. Cables in embedded conduits are protected from adverse conditions occurring due to fire suppression effects. Therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2204 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-EMBED-AB - Aux Building Embedded Conduit Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2205 of 2430

0 Attachat C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-EMBED-AB - Aux Building Embedded Conduit Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2206 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SO1 - Stairwell No. 1 Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SO1 Stairwell No. 1 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2207 of 2430 0

Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SO1 - Stairwell No. 1 Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2208 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S01 - Stairwell No. 1 Performance Goals Compliance Basis: Unit 2: NFPA 805ISection 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 808! Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                    " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                    " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                    " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2209 of 2430 0 S

0 Attach~t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SO1 - Stairwell No. 1 Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2210 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-92 Table B-3) Fire Area ID: 2-SO1 - Stairwell No. 1 Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2211 of 2430 0

0 Attachft C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S01 - Stairwell No. 1 Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Detection 2A-1 10 EEEE/LA Required to support a fire area boundary evaluation. Detection 2A-1 10 DID Criteria Required to meet DID criteria. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2212 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S01 - Stairwell No. 1 Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-S01 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation the installed detection system, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.75E-09 A LERF 1.62E-12 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed detection system was identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2213 of 2430 0

0Attach~t Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) C 0 Fire Area ID: 2-S01 - Stairwell No. 1 VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-S01-SEP-001 VFDR Q2N1 1PV3371 C:CLOSED:CLOSED, MAIN STEAM ATMOS RELIEF - The Atmospheric Relief Valves are required to isolate the secondary side initially, for all steam generators, in order to contain SG Pressure. Fire induced circuit failure to MSARV 3371C could result in the valve spuriously opening. This failure challenges the Decay Heat Removal Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2214 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area iD: 2-S02 - Stairwell No. 2 Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-S02 Stairwell No. 2 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2215 of 2430 0 0 i6

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-S02 - Stairwell No. 2 Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power.

                                                   " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup " Unit 2: RCS inventory is controlled using Train A charging pump or swing charging pump via Train A power aligned to the RWST.

                                                   " Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

                                                   " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2216 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S02 - Stairwell No. 2 Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                 " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/lC. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                 " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/iC pressure is monitored. 6. SG Level- Steam Generator 1A/1B/iC level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                 " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2217 of 2430

0 Attachi Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) tC Fire Area ID: 2-S02 - Stairwell No. 2 Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water - Unit 2: Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

  • Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train A component cooling water is provided with non-essential loads isolated.
  • Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated.

7.4 Vital Auxiliaries HVAC - Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.

                                                      - Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2218 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S02 - Stairwell No. 2 Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2219 of 2430 0

0 Attachl tC 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S02 - Stairwell No. 2 Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Detection 2A-108 EEEE/LA Required to support a fire area boundary evaluation. Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Passive Three Hour Rated Enclosure Risk Criteria Required to meet the risk criteria. Passive Three Hour Rated Enclosure Separation Required to support the NSCA. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2220 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S02 - Stairwell No. 2 Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-S02 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of existing promat H board for cable protection, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF Epsilon A LERF Epsilon DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2221 of 2430

0 Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-S02 - Stairwell No. 2 VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-S02-HVAC-002 VFDR Q2R15A0006:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2F - This component, Switchgear 2F (600V Load Center D Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2222 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S08 - Stairwell No. 8 Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-S08 Stairwell No. 8 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2223 of 2430 0

0 Attachft C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table 'B-3) 0 Fire Area ID: 2-S08 - Stairwell No. 8 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2224 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S08 - Stairwell No. 8 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                    " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                    " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

  • Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1PA/i /10C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                    " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2225 of 2430 0

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SO8 - Stairwell No. 8 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2226 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S08 - Stairwell No. 8 Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptab*.ty:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2227 of 2430 0 0

0 Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S08 - Stairwell No. 8 Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2228 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S08 - Stairwell No. 8 Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments J! Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2229 of 2430 0 0 0

O Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S10 - Stairwell No. 10 0ire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-S10 Stairwell No. 10 Fire Safety Analysis Data Manager (4. 1) Farley .. Run: 08/18/2012 22:12 Page: 2230 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S10 - Stairwell No. 10 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2231 of 2430 0 0 0

Attachbt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-S10 - Stairwell No. 10 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                    " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR. narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                    " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored, 6. SG Level - Steam Generator 1A/M B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

  • Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2232 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S10 - Stairwell No. 10 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2233 of 2430 0 0 0

0 AttachIt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) S Fire Area ID: 2-S1 - Stairwell No. 10 Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2234 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S10 - Stairwell No. 10 Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Passive Restricted transient controls EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2235 of 2430 0 0

SAttacht C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-S10 - Stairwell No. 10 Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. " CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2236 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB1-A Service Water Valve Box, 2-SVB1, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2237 of 2430

0 Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power.

                                                 " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup " Unit 2: RCS inventory is controlled using Train B charging pump or swing charging pump via Train B power aligned to the RWST.

                                                 " Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2238 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                " Unit 1: 1. Electrical power is supplied by off-site powervia SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2239 of 2430

                                                                                                 .0

Tnmhic r-1 PMFPAn% rAh Attach~t C l A Cenm iiann,- Immi flA..fl TfihIin PZ.1 0 Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water

  • Unit 2: Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
  • Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train B component cooling water is provided with non-essential loads isolated.

9 Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC

  • Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.
  • Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2240 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

  • The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2241 of 2430

0 Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2242 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-SVB1-A Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 7.77E-1 1 A LERF 1.17E-13 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2243 of 2430 0

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A VFDRs Compliance Basis: Unit 2: NFPA 805,.Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-SVB1-A-HVAC-001 VFDR Q2R42B0001A:ENERGIZED:ENERGIZED-BC2A, 125V DC BUS 2A - This component, 125V DC Bus 2A (Train A Battery Charger Room Cooler), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-SVB1-A-HVAC-002 VFDR Q2R15A0006:ENERGIZED:ENERGIZED-SUT2B, 4160V SWITCHGEAR BUS 2F - This component, Switchgear 2F (600V Load Center D Room Cooler), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB1-A-HVAC-003 VFDR Q2R17B0001:ENERGIZED:ENERGIZED, MOTOR CONTROL CENTER 2A - This component, MCC A (Room Cooler), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2244 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB1-B Service Water Valve Box, 2-SVB1, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2245 of 2430

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table:B-3) 0 Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical

                                                 " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions                                          boron dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power.
                                                 " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup " Unit 2: RCS inventory is controlled using Train A charging pump or swing charging pump via Train A power aligned to the RWST.

  • Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity

                                                 " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.
                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2246 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2247 of 2430

                                                                                                .S

Attach~t C Table C-1 NFPA 8Q5 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Perform ahce-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water

  • Unit 2: Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided .with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
  • Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train A component cooling water is provided with non-essential loads isolated.
  • Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated.

7.4 Vital Auxiliaries HVAC

  • Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance based approach HVAC equipment corresponding to the service water train.
                                                       - Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2248 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2249 of 2430

S Attachlt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805. Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By CoMments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2250 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-SVB1-B Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 8.76E-1 1 A LERF 1.67E-1 3 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2251 of 2430

Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-SVB1-B-HVAC-001 VFDR Q2R42B0001B:ENERGIZED:ENERGIZED-BC2B, 125V DC BUS 2B - This component, 125V DC Bus 2B (Train B Battery Charger Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-SVB1-B-HVAC-002 VFDR Q2R15A0007:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2G - This component, Switchgear 2G (600V Load Center E Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB1-B-HVAC-003 VFDR Q2R17B0002:ENERGIZED:ENERGIZED, MOTOR CONTROL CENTER 2B - This component, MCC 2B, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2252 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB2-A Service Water Valve Box, 2-SVB2, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2253 of 2430 0

Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table 'B-3) 0 Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical

                                                 " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions                                          boron dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power.
                                                 " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup " Unit 2: RCS inventory is controlled using Train B charging pump or swing charging pump via Train B power aligned to the RWST.

                                                 " Unit 1: Unit 1: RCS inventory is controlled using Train A charging pump:

Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity

                                                 " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.
                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2254 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2255 of 2430 0 0

S.Attachlt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.1 Vital Auxiliaries Electrical

  • Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
  • Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16. kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water

  • Unit 2: Performance-based approach Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
  • Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train B component cooling water is provided with non-essential loads isolated.

9 Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC - Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.

  • Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2256 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

  • The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2257 of 2430 0

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Passive Restricted transient controls DID Criteria Required to meet DID criteria. Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2258 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-SVB2-A Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions and the procedure enhancements to limit transients, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 2.15E-08 A LERF 7.55E-1 1 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, procedure enhancements to limit transients were identified as require for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2259 of 2430 0

0 Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) S Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-SVB2-A-HVAC-001 VFDR Q2R42BO001A:ENERGIZED:ENERGIZED-BC2A, 125V DC BUS 2A - This component, 125V DC Bus 2A (Train A Battery Charger Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical Component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-SVB2-A-HVAC-002 VFDR Q2R15A0006:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2F - This component, Switchgear 2F (600V Load Center D Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC Support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB2-A-HVAC-003 VFDR Q2R17B0001 :ENERGIZED:ENERGIZED, MOTOR CONTROL CENTER 2A - This component, MCC 2A (Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical Component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB2-A-SEP-001 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2260 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2P16V0538:CLOSED:OPEN, SW RECIRC TO POND TRAIN B - Recirculation to the Pond is the credited lineup for service water. It is for this reason that the SW Emergency Recirc Valve to the pond must open. Fire induced control circuit damage to valve 02P16V0538 could result in spurious isolation of the pond recirc path. This failure challenges the establishment of Service Water and various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-SVB2-A-SEP-002 VFDR Q2P16V0545:OPEN:OPEN/CLOSED, TRAIN B SW DISCHARGE TO RIVER - Recirculation to the Pond is the credited lineup for service water. It is for this reason that the SW Discharge to the River must be isolated. Fire induced control circuit damage to valve Q2P16V0545 could result in spurious opening of the river discharge path. This failure challenges the establishment of Service Water and various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2261 of 2430 0 0

0 Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB2-B Service Water Valve Box, 2-SVB2, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2262 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power.

                                                 " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup " Unit 2: RCS inventory is controlled using Train A charging or swing charging pump via Train A power aligned to the RWST.

                                                 " Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2263 of 2430 0

Attachot C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3* 0 Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring

  • Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.
                                                " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical

                                                " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
                                                " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2264 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water

  • Unit 2: Performance-based approach Train A service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
  • Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train A component cooling water is provided with non-essential loads isolated.
                                                       - Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated.

7.4 Vital Auxiliaries HVAC - Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train. e Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2265 of 2430 0

0 Attachi tC " Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adfequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2266 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2267 of 2430 0 0

0 AttachQt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-SVB2-B Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.51E-13 A LERF 3.63E-1 7 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2268 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-SVB2-B-HVAC-001 VFDR Q2R42BOO01B:ENERGIZED:ENERGIZED-BC2B, 125V DC BUS 2B - This component, 125V DC Bus 2B, requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-SVB2-B-HVAC-002 VFDR Q2R15A0007:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2G - This component, Switchgear 2G (600V Load Center Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB2-B-HVAC-003 VFDR Q2R42E0002B:AVAILABLE:AVAILABLE, 125V BATTERY 2B - This component, Battery 2B (Train B Battery Room Exhaust Fan), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB2-B-SEP-001 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2269 of 2430 0

Attachet C i Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2P16V0539:CLOSED:OPEN, SW RECIRC TO POND TRAIN A - Recirculation to the Pond is the credited lineup for service water. It is for this reason that the SW Emergency Recirc Valve to the pond must open. Fire induced control circuit damage to valve Q2P1 6V0539 could result in spurious isolation of the pond recirc path. This failure challenges the establishment of Service Water and various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-SVB2-B-SEP-002 VFDR Q2P16V0546:OPEN:OPEN/CLOSED, TRAIN A SW DISCHARGE TO RIVER - Recirculation to the Pond is the credited lineup for service water. It is for this reason that the SW Discharge to the River must be isolated. Fire induced control circuit damage to valve Q2P16V0546 could result in spurious opening of the river discharge path. This failure challenges the establishment of Service Water and various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2270 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB3-A Service Water Valve Box, 2-SVB3, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2271 of 2430 0

0 Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical " Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train B charging pump or swing charging pump via Train B power.

                                                 " Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup " Unit 2: RCS inventory is controlled using Train B charging pump or swing charging pump via Train B power aligned to the RWST.

                                                 " Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity " Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train B charging pump or swing charging pump via Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.

                                                 " Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2272 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2273 of 2430

Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water

  • Unit 2: Train B service water is provided with two service water pumps in service recirculating to the pond or Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
                                                       ° Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train B component cooling water is provided with non-essential loads isolated.
  • Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated.

7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2274 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 " The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2275 of 2430

Attachet C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2276 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-SVB3-A Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. " CDF 8.31 E-11 A LERF 1.38E-1 3 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2277 of 2430 0

0 Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-SVB3-A-HVAC-001 VFDR Q2R42B0001A:ENERGIZED:ENERGIZED-BC2A, 125V DC BUS 2A - This component, 125V DC Bus 2A (Train A Battery Charger Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-SVB3-A-HVAC-002 VFDR Q2R15A0006:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2F - This component, Switchgear 2F (600V Load Center D Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB3-A-HVAC-003 VFDR Q2R17B0001:ENERGIZED:ENERGIZED, MOTOR CONTROL CENTER 2A - This component, MCC 2A (MCC 2A Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2278 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB3-B Service Water Valve Box, 2-SVB3, Train B Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2279 of 2430

9 Attach&t C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table 8-3) Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical

  • Unit 2: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power.
  • Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent boron dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging. pump via Train A/Train B power.

3.1 RCS Inventory Control - RCS Makeup

  • Unit 2: RCS inventory is controlled using Train A charging pump or swing charging pump via Train A power aligned to the RWST.
  • Unit 1: RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST.

3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity

  • Unit 2: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve.
  • Unit 1: Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines.

CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2280 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                               " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A12B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                               " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                               " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2281 of 2430

0 AttachIt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.2 Vital Auxiliaries Service Water

  • Unit 2: Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.
                                                       - Unit 1: Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated.

7.3 Vital Auxiliaries Component Cooling Water

  • Unit 2: Train A component cooling water is provided with non-essential loads isolated.
  • Unit 1: Train A/Train B component cooling water is provided with non-essential loads isolated.

7.4 Vital Auxiliaries HVAC

  • Unit 2: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train.
  • Unit 1: Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train.

Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2282 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2283 of 2430

                 .                                                                Attach            tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3)

Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2284 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-SVB3-B Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 9.1OE-11 A LERF 1.77E-1 3 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2285 of 2430 0

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-SVB3-B-HVAC-001 VFDR Q2R42B0001B:ENERGIZED:ENERGIZED-BC2B, 125V DC BUS 2B - This component, 125V DC Bus 2B (Train B Battery Charger Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC Support to this electrical component challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-2-SVB3-B-HVAC-002 VFDR Q2R15A0007:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2G - This component, Switchgear 2G (600V Load Center E Room Cooler), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-2-SVB3-B-HVAC-003 VFDR Q2R42E0002B:AVAILABLE:AVAILABLE, 125V BATTERY 2B - This component, Battery 2B (Train B Battery Room Exhaust Fan), requires HVAC support to remain functional. Failure to provide HVAC support to this electrical component challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2286 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-A - Service Water Valve Box, 2-SVB4, Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB4-A Service Water Valve Box, 2-SVB4, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2287 of 2430 0

0 Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table'B-3) Fire Area ID: 2-SVB4-A - Service Water Valve Box, 2-SVB4, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2288 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-A - Service Water Valve Box, 2-SVB4, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

  • Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level- Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2289 of 2430 0

0 Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-A - Service Water Valve Box, 2-SVB4, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2290 of 2430

Attachment C Table o-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-A - Service Water Valve Box, 2-SVB4, Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2291 of 2430 49 0

S Attach~tC 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-B - Service Water Valve Box, 2-SVB4, Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-SVB4-B Service Water Valve Box, 2-SVB4, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2292 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-B - Service Water Valve Box, 2-SVB4, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2293 of 2430

0 Attach/t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-B - Service Water Valve Box, 2-SVB4, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                  " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1 B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2294 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-B - Service Water Valve Box, 2-SVB4, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2295 of 2430 0

0 ~Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-SVB4-B - Service Water Valve Box, 2-SVB4, Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2296 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) I Fire Area ID: 2-SVB4-B - Service Water Valve Box, 2-SVB4, Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2297 of 2430 0

AttachQt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) S Fire Area ID: 2-TB - Turbine Building General Area Fire Area Definition Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description 2-084 Turbine, SGFP, and H2 Seal Oil Conditioners & Reservoirs 2-085 Turbine Building, General Area 2-0851 I- El. 189'-0", Entire Floor (less Zone H) and Platform at El. 207'-0" 2-087 Steam Generator Feed Pumps A & B 2-088 Turbine Building Switchgear Area Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2298 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by performance

                                                  -based approach tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers.

RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are performance-based approach shut off. Undesired pressure increase is prevented by performanced- based approach deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2299 of 2430

SAttach. tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal " Unit 2: Performance-based approach decay heat removal during HSD!is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.

                                                   " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring

  • Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.
                                                   " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1 B/1C level is monitored.

7.1 Vital Auxiliaries Electrical

                                                   " Unit 2: 1. Electrical power is supplied by diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.
                                                   " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2300 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area Performance Goals Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved utilizing equipment and cables that have been reviewed to be unaffected by the effects of fire suppression activities in the area and adjacent areas. Drainage capacity in the general Turbine Building area exceeds expected fire suppression flows. Local hazards protected by sprinkler or water spray systems have sufficient curbing and discharage of manual suppression water in adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2301 of 2430

6AttachtC0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area Engineering Evaluations Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS. RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

  • The fire areas, fire zones and rooms on both sides of the barrier were identified, 9 The construction of the boundary and the potential issue with the element in question was described,
  • The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
  • The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2302 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area Required Fire Protection Systems and Features Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Detection 2T-12A(D) (2-084] DID Criteria Required to meet DID criteria. Detection 2T-12B(D) (2-084] DID Criteria Required to meet DID criteria. Detection 2T-16A DID Criteria Required to meet DID criteria. Detection 2T-16B DID Criteria Required to meet DID criteria. Detection 2T-16C DID Criteria Required to meet DID criteria. Detection 2T-16D DID Criteria Required to meet DID criteria. Detection 2T-16E DID Criteria Required to meet DID criteria. Detection 2T-17 DID Criteria Required to meet DID criteria. Detection 2T-20 DID Criteria Required to meet DID criteria. Gaseous Suppression 2T-13 Risk Criteria Required to meet risk criteria. Gaseous Suppression 2T-14 Risk Criteria Required to meet risk criteria. Water Suppression 2T-10 DID Criteria Required to meet DID criteria. Water Suppression 2T-121 DID Criteria Required to meet DID criteria. Water Suppression 2T-12A DID Criteria Required to meet DID criteria. Water Suppression 2T-12B DID Criteria Required to meet DID criteria. Water Suppression 2T-16A DID Criteria Required to meet DID criteria. Water Suppression 2T-16B DID Criteria Required to meet DID criteria. Water Suppression 2T-16C DID Criteria Required to meet DID criteria. Water Suppression 2T-16D DID Criteria Required to meet DID criteria. Water Suppression 2T-16E DID Criteria Required to meet DID criteria. Water Suppression 2T-17 DID Criteria Required to meet DID criteria. Water Suppression 2T-2 DID Criteria Required to meet DID criteria. Water Suppression 2T-20 DID Criteria Required to meet DID criteria. Water Suppression 2T-3 DID Criteria Required to meet DID criteria. Water Suppression 2T-5A DID Criteria Required to meet DID criteria. Water Suppression 2T-5B DID Criteria Required to meet DID criteria. Water Suppression 2T-7A DID Criteria Required to meet DID criteria. Water Suppression 2T-7B DID Criteria Required to meet DID criteria. Water Suppression 2T-7C DID Criteria Required to meet DID criteria. Water Suppression 2T-8 DID Criteria Required to meet DID criteria. Water Suppression 2T-9 DID Criteria Required to meet DID criteria. Modifications Risk Criteria Modification to provide fuse or other electrical isolation device at the DC shunt connection point. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2303 of 2430 0

AttachQt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area Fire Risk Evaluation Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Title FRE for Fire Area 2-TB Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of the modification to provide fuse or other electrical isolation device at the DC shunt connection point and the installed detection/suppression systems, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 2.67E-07 A LERF 1.09E-09 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed detection and suppression (manual and automatic activation) systems were identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2304 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-TB-IA-001 VFDR Q2E21V0243:CLOSED:CLOSED, RCS ALTERNATE CHARGING LINE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Isolating the alternate charging line is necessary in order to obtain a significant pressure gradient in order to de-pressurize the RCS via aux-spray. This valve (the Alternate Charging line supply from CVCS) fails open on a loss of instrument air, and hence the necessary pressure gradient will not be sufficient to supply the pressurizer through the spray line. Failure to de-pressurize via aux spray challenges the RCS Pressure/Inventory Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-IA-002 VFDR Q2E21V0244:OPEN:MODULATE, RCS NORMAL CHARGING LINE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. An inability to modulate this valve due to a loss of instrument air would prevent de-pressurization of the RCS system to accommodate RCS transients. Failure to ensure cycling capability of this valve challenges the RCS Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-IA-003 VFDR Q2E21V0245:CLOSED:OPEN/CLOSED, RCS PRESSURIZER AUX SPRAY - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. This valve is required to cycle in order to supply CVCS inventory to the pressurizer to de-pressurize via aux-spray, and the valve fails closed on a loss of instrument air. An inability to cycle this valve due to a loss of instrument air would prevent de-pressurization of the RCS via aux-spray. Failure to ensure cycling capability of this valve challenges the RCS Pressure/Inventory Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2305 of 2430

Attachist C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-TB - Turbine Building General Area VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR ID U2-2-TB-IA-004 VFDR Q2E21V0347:MODULATED:MODULATE, CHARGING FLOW CONTROL VALVE - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Flow control Valve V0347 permits normal charging flow to be injected into the RCS system. Instrument air is required to control the flow and thus charging inventory that is injected into the RCS Cold Legs. A loss of instrument air could result in this valve failing in the open position. Failure to throttle flow to the RCS system challenges the RCS Inventory/Pressure Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-IA-005 VFDR Q2N1 1PV3371 A:CLOSED:MODULATE, MAIN STEAM ATMOS RELIEF - This component requires instrument air to perform its credited function. Instrument air is assumed to be unavailable in this fire area because air loss paths have not been identified. Atmospheric relief on the secondary side is necessary in order to 2A ARV due to a loss of instrument air would cause the valve to fail closed. This failure challenges the Decay Heat Removal Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-SEP-001 VFDR Q2B41PO001A:ON:OFF, RCP 2A - In order to achieve and maintain a natural circulation cool down, the Reactor Coolant Pumps must be tripped. A loss of control power to RCP 2A would prevent the Pump from being tripped from the control room. Failure to trip the RCP challenges the RCS Inventory Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-SEP-002 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2306 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: 2-TB - Turbine Building General Area VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2B41P0001B:ON:OFF, RCP 2B - In order to achieve and maintain a natural circulation cool down, the Reactor Coolant Pumps must be tripped. A loss of control power to RCP 2B would prevent the Pump from being tripped from the control room. Failure to trip the RCP challenges the RCS Inventory Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-SEP-003 VFDR Q2841 P0001 C:ON:OFF, RCP 2C - In order to achieve and maintain a natural circulation cool down, the Reactor Coolant Pumps must be tripped. A loss of control power to RCP 2C would prevent the Pump from being tripped from the control room. Failure to trip the RCP challenges the RCS Inventory Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-SEP-004 VFDR N2N21PO001A:ON/STANDBY:OFF, CONDENSATE PUMP 2A - Decay Heat Removal via Auxiliary Feed water is credited, therefore all Main Feed water supplies need to be isolated. The Condensate Pumps supply feed water to the Main Feed pumps, which are not credited for cool down. Fire induced circuit failures could cause spurious operation of all condensate pumps for a fire in the turbine building. A loss of control power would also prevent remote tripping of the condensate pumps. Failure to secure the condensate feed challenges the Decay Heat Removal Nuclear Safety Performance Goal. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-SEP-005 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2307 of 2430 0

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: 2-TB - Turbine Building General Area VFDRs Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach VFDR Q2N23PO001A:OFF:ON/OFF, 2A MDAFW PUMP - The Auxiliary Feed water Pump is required to supply feed water to the Steam Generators in order to remove decay heat. Fire induced circuit failure in this fire area could prevent operation of the Motor Driven AFW Pumps (2A and 2B) and/or result in spurious tripping of the pumps. Failure to ensure the availability of Pump 2A or 2B challenges the Decay Heat Removal Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-2-TB-SEP-006 VFDR N2B31 L0001 C:ON:OFF, PRESSURIZER HEATER GROUP 2C DISTRIBUTION PANEL - A loss of control power to the pressurizer heaters would prevent the ability to trip the pressurizer heaters. Heater Groups C and D suffer a loss of power from panel 2G. Spurious heater operation could impact the fluid conditions within the pressurizer. If specific pressure conditions cannot be maintained, than the ability to de-pressurize is compromised This failure challenges the RCS Pressure Control Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 . Page: 2308 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U1 - Control Room Air Conditioner, Unit 1 & Unit 2 Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description ABRF1 -U1 Control Room Air Conditioner/Unit 1 Side ABRF2-U1 Control Room Air Conditioner/Unit 2 Side Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2309 of 2430 0

0 Attach~t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U1 - Control Room Air Conditioner, Unit 1 & Unit 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B: power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2310 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U1 - Control Room Air Conditioner, Unit 1 & Unit 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment I Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by performance-based approach Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2311 of 2430

0 Attach~t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U1 - Control Room Air Conditioner, Unit 1 & Unit 2 Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2312 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U1 - Control Room Air Conditioner, Unit 1 & Unit 2 Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area ABRF-U1 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF Epsilon A LERF Epsilon DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2313 of 2430

AttachftC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: ABRF-U1 - Control Room Air Conditioner, Unit 1 & Unit 2 VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID Ul-ABRF-SEP-001 VFDR QSV49KO001A:STANDBY:ON, CONTROL ROOM PACKAGE A/C BLOWER UNIT A - Control Room HVAC is required to provide habitable conditions for operations to perform the necessary actions to achieve hot standby/hot shutdown from the control room. Both Train A and Train B related HVAC equipment (Blowers and A/C Units) are impacted in this area, due to the physical presence of the fire. This failure challenges a critical vital auxiliary Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2314 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U2 - Control Room Air Conditioner, Unit 1 & Unit 2 Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description ABRF1-U2 Control Room Air Conditioner/Unit 1 Side ABRF2-U2 Control Room Air Conditioner/Unit 2 Side Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2315 of 2430 0

0 Attachl tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U2 - Control Room Air Conditioner, Unit 1 & Unit 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or contaigment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2316 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U2 - Control Room Air Conditioner, Unit 1 & Unit 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by performance-based approach Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. F Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2317 of 2430 0

0 Attach*t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U2 - Control Room Air Conditioner, Unit 1 & Unit 2 Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2318 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: ABRF-U2 - Control Room Air Conditioner, Unit 1 & Unit 2 Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area ABRF-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF Epsilon A LERF Epsilon DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2319 of 2430

          &                                                                          Attachlt C                                                                                           0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3)

Fire Area ID: ABRF-U2 - Control Room Air Conditioner, Unit 1 & Unit 2 VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-ABRF-SEP-001 VFDR QSV49KO001A:STANDBY:ON, CONTROL ROOM PACKAGE A/C BLOWER UNIT A - Control Room HVAC is required to provide habitable conditions for operations to perform the necessary actions to achieve hot standby/hot shutdown from the control room. Both Train A and Train B related HVAC equipment (Blowers and A/C Units) are impacted in this area, due to the physical presence of the fire. This failure challenges a critical vital auxiliary Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2320 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-A - Diesel Fuel Oil Storage Tank Ductbank, Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description DU-DGFOST-A Diesel Fuel Storage Tank Ductbank, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2321 of 2430 S 0

S:Attachit C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-A - Diesel Fuel Oil Storage Tank Ductbank, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the sLjpply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2322 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-A - Diesel Fuel Oil Storage Tank Ductbank, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                  " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
  • Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring

  • Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.
                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

  • Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2323 of 2430

Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: DU-DGFOST-A - Diesel Fuel Oil Storage Tank Ductbank, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2324 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-A - Diesel Fuel Oil Storage Tank Ductbank, Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2325 of 2430 0

AttachftC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: DU-DGFOST-A - Diesel Fuel Oil Storage Tank Ductbank, Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2326 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-B - Diesel Fuel Oil Storage Tank Ductbank, Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description DU-DGFOST-B Diesel Fuel Storage Tank Ductbank, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2327 of 2430 0

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: DU-DGFOST-B - Diesel Fuel Oil Storage Tank Ductbank, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlle' using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. . 5 Decay Heat Removal

                                                 " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
  • Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2328 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-B - Diesel Fuel Oil Storage Tank Ductbank, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 6 Process Monitoring

  • Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.
  • Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/IB/1C level is monitored.

7.1 Vital Auxiliaries Electrical

  • Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 28, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

9 Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2329 of 2430 0 0 0

S Attachit C 1 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-B - Diesel Fuel Oil Storage Tank Ductbank, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2330 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-DGFOST-B - Diesel Fuel Oil Storage Tank Ductbank, Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2331 of 2430 0

Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: DU-DGFOST-B - Diesel Fuel Oil Storage Tank Ductbank, Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2332 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U1 - SWIS to Valve Box Ductbank, Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description DU-SWISVB-A- SWIS to Valve Box Ductbank, Train A U1 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2333 of 2430

0 Attach&t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U1 - SWIS to Valve Box Ductbank, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train. A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned.to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2334 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U1 - SWIS to Valve Box Ductbank, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Performance-based approach Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2335 of 2430 0 0

SAttachQt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U1 - SWIS to Valve Box Ductbank, Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2336 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U1 - SWIS to Valve Box Ductbank, Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area DU-SWISVB-A-U1 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.57E-1 3 A LERF 3.64E-17 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2337 of 2430 0 0

0 ~Attach~t C i Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U1 - SWIS to Valve Box Ductbank, Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID Ul -DU-SWISVB-A-SEP-001 VFDR QSP16V0507:OPEN:OPEN, SW TO POND EAST HEADER ISOLATION - This valve or the wet pit discharge valve must be open to provide return path for service water. Fire induced circuit failure to valve QSP16V0507 and QSP16V0505 could result in spurious isolation of return line. This failure challenges the Vital Auxiliaries Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2338 of 2430

Attachment C .1 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U2 - SWIS to Valve Box Ductbank, Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description DU-SWISVB-A- SWIS to Valve Box Ductbank, Train A U2 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2339 of 2430 0 0

S Attaciat Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) C Fire Area ID: DU-SWISVB-A-U2 - SWIS to Valve Box Ductbank, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2340 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U2 - SWIS to Valve Box Ductbank, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries Electrical 1.Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B.2.4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment.3.125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Performance-based approach Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2341 of 2430

0 AttachIt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: DU-SWISVB-A-U2 - SWIS to Valve Box Ductbank, Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2342 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U2 - SWIS to Valve Box Ductbank, Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area DU-SWISVB-A-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins.The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.51 E-13 A LERF 3.63E-1 7 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2343 of 2430

Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-A-U2 - SWIS to Valve Box Ductbank, Train A " VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-DU-SWISVB-A-SEP-001 VFDR QSP16VO507:OPEN:OPEN, SW TO POND EAST HEADER ISOLATION - This valve or the wet pit discharge valve must be open to provide return path for service water. Fire induced circuit failure to valve QSP16V0507 and QSP16V0505 could result in spurious isolation of return line. This failure challenges the Vital Auxiliaries Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2344 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U1 - SWIS to Valve Box Ductbank, Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description DU-SWISVB-B- SWIS to Valve Box Ductbank, Train B U1 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2345 of 2430 0 0

0 Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U1 - SWIS to Valve Box Ductbank, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW

                                                .pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2346 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U1 - SWIS to Valve Box Ductbank, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2347 of 2430 0

0 Attach tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U1 - SWIS to Valve Box Ductbank, Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
  • The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2348 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U1 - SWIS to Valve Box Ductbank, Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area DU-SWISVB-B-U1 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.57E-13 A LERF 3.64E-17 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2349 of 2430 0 0 S

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: DU-SWISVB-B-U1 - SWIS to Valve Box Ductbank, Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U1-DU-SWISVB-B-SEP-001 VFDR QSP16VO508:OPEN:OPEN, SW TO POND EAST HEADER ISOLATION - This valve or the wet pit discharge valve must be open to provide return path for service water. Fire induced circuit failure to valve QSP16V0508 and QSP16V0506 could result in spurious isolation of return line. This failure challenges the Vital Auxiliaries Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based al proach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4-1) Farley Run: 08/18/2012 22:12 Page: 2350 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U2 - SWIS to Valve Box Ductbank, Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description DU-SWISVB-B- SWIS to Valve Box Ductbank, Train B U2 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2351 of 2430 0 0

0 Attachet C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U2 - SWIS to Valve Box Ductbank, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2352 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U2 - SWIS to Valve Box Ductbank, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries Electrical 1.Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B.2.4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment.3.125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Performance-based approach Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2353 of 2430 0

Attach tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U2 - SWIS to Valve Box Ductbank, Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
  • The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2354 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U2 - SWIS to Valve Box Ductbank, Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area DU-SWISVB-B-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.51 E-13 A LERF 3.63E-17 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Ahalysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2355 of 2430 0

Attache t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: DU-SWISVB-B-U2 - SWIS to Valve Box Ductbank, Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-DU-SWISVB-B-SEP-001 VFDR QSP16VO508:OPEN:OPEN, SW TO POND EAST HEADER ISOLATION - This valve or the wet pit discharge valve must be open to provide return path for service water. Fire induced circuit failure to valve QSP16V0508 and QSP16V0506 could result in spurious isolation of return line. This failure challenges the Vital Auxiliaries Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2356 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U1 - Diesel Generator Building Embedded Conduit Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description EMBED-DGB-U1 Embedded Conduit, Diesel Generator Building Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2357 of 2430 S 0

Attachet C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U1 - Diesel Generator Building Embedded Conduit Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2358 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U1 - Diesel Generator Building Embedded Conduit Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained in this area due to embedded conduits. Cables in embedded conduits are protected from adverse conditions occurring due to fire suppression effects. Therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2359 of 2430

Attachlt C0 Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U1 - Diesel Generator Building Embedded Conduit Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                               " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
                               " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2360 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U1 - Diesel Generator Building Embedded Conduit Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2361 of 2430 p

9 Attac-t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U2 - Diesel Generator Building Embedded Conduit Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description EMBED-DGB-U2 Embedded Conduit, Diesel Generator Building Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2362 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U2 - Diesel Generator Building Embedded Conduit Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2363 of 2430 0t

0 Attachot C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U2 - Diesel Generator Building Embedded Conduit Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries Electrical 1.Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B.2.4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment.3.125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained in this area due to embedded conduits. Cables in embedded conduits are protected from adverse conditions occurring due to fire suppression effects. Therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2364 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U2 - Diesel Generator Buildir)g Embedded Conduit Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units I and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
  • The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2365 of 2430

Attachl tC 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: EMBED-DGB-U2 - Diesel Generator Building Embedded Conduit Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2366 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U1 - Service Water Valve Box Return to Wet Pit, Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description SWWPVB-A-U1 Service Water Valve Box Return to Wet Pit, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2367 of 2430 0

0' Attachlt C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U1 - Service Water Valve Box Return to Wet Pit, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using, Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2368 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U1 - Service Water Valve Box Return to Wet Pit, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1 B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2369 of 2430 S,

0 Attach~t C 00 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U1 - Service Water Valve Box Return to Wet Pit, Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                               " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                               " The construction of the boundary and the potential issue with the element in question was described,
                               " The fire hazards and fire protection features on both sides of the barrier were described,
                               " Elements with construction features equal to 3-hr boundaries were credited as such,
                               " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2370 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U1 - Service Water Valve Box Return to Wet Pit, Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area SWWPVB-A-U1 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.94E-10 A LERF 4.51 E-14 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2371 of 2430

0 Attachft C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: SWWPVB-A-U1 - Service Water Valve Box Return to Wet Pit, Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U1-SWWPVB-A-SEP-001 VFDR QSP1 6V0505:CLOSED:OPEN/CLOSED, SW TO WET PIT EAST HEADER ISOLATION - Simultaneous closure of both service water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train A. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train A would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Sectroq 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID Ul-SWWPVB-A-SEP-002 VFDR QSP16V0507:OPEN:OPEN, SW TO POND EAST HEADER ISOLATION - Simultaneous closure of both service water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train A. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train A would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2372 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U2 - Service Water Valve Box Return to Wet Pit, Train A Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description SWWPVB-A-U2 Service Water Valve Box Return to Wet Pit, Train A Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2373 of 2430 0

0 Attachit C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U2 - Service Water Valve Box Return to Wet Pit, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2374 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U2 - Service Water Valve Box Return to Wet Pit, Train A Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel. generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Performance-based approach Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2375 of 2430

0 Attach~t C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U2 - Service Water Valve Box Return to Wet Pit, Train A Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2376 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U2 - Service Water Valve Box Return to Wet Pit, Train A Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area SWWPVB-A-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.87E-10 A LERF 4.51 E-14 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. I. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2377 of 2430

Attacht C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-A-U2 - Service Water Valve Box Return to Wet Pit, Train A VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-SWWPVB-A-SEP-001 VFDR QSP1 6V0505:CLOSED:OPEN/CLOSED, SW TO WET PIT EAST HEADER ISOLATION - Simultaneous closure of both service water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train A. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train A would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-SWWPVB-A-SEP-002 VFDR QSP16V0507:OPEN:OPEN, SW TO POND EAST HEADER ISOLATION - Simultaneous closure of both service water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train A. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train A would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2378 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-U1 - Service Water Valve Box Return to Wet Pit, Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description SWWPVB-B-U1 Service Water Valve Box Return to Wet Pit, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2379 of 2430 0 .0 0

0 Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: SWWPVB-B-U1 - Service Water Valve Box Return to Wet Pit, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump or swing charging pump via Train A power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2380 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-Ul - Service Water Valve Box Return to Wet Pit, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Performance-based approach Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2381 of 2430 0

0 Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-U1 - Service Water Valve Box Return to Wet Pit, Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                 " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                 " The construction of the boundary and the potential issue with the element in question was described,
                                 ' The fire hazards and fire protection features on both sides of the barrier were described,
                                 " Elements with construction features equal to 3-hr boundaries were credited as such,
                                 " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2382 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-U1 - Service Water Valve Box Return to Wet Pit, Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area SWWPVB-B-U1 . Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.94E-1 0 A LERF 4.51 E-14 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2383 of 2430

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-t61 - Service Water Valve Box Return to Wet Pit, Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID Ul-SWWPVB-B-SEP-001 VFDR QSP16V0506:CLOSED:OPEN/CLOSED, SW TO WET PIT WEST HEADER ISOLATION - Simultaneous closure of both Service Water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train B. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train B would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. E£'aluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID Ul-SWWPVB-B-SEP-002 VFDR QSP16V0508:OPEN:OPEN, SW TO POND WEST HEADER ISOLATION - Simultaneous closure of both Service Water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train B. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train B would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2384 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-U2 - Service Water Valve Box Return to Wet Pit, Train B Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description SWWPVB-B-U2 Service Water Valve Box Return to Wet Pit, Train B Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2385 of 2430 0

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: SWWPVB-B-U2 - Service Water Valve Box Return to Wet Pit, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2386 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-U2 - Service Water Valve Box Return to Wet Pit, Train B Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Performance-based approach Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled and watertight barriers exist between divisions; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2387 of 2430 0

0 Attach~t C i Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-U2 - Service Water Valve Box Return to Wet Pit, Train B Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated .reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2388 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: SWWPVB-B-U2 - Service Water Valve Box Return to Wet Pit, Train B Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area SWWPVB-B-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 1.87E-1 0 A LERF 4.51 E-14 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2389 of 2430

Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: SWWPVB-B-U2 - Service Water Valve Box Return to Wet Pit, Train B VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-SWWPVB-B-SEP-001 VFDR QSP16V0506:CLOSED:OPEN/CLOSED, SW TO WET PIT WEST HEADER ISOLATION - Simultaneous closure of both Service Water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train' B. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train B would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-SWWPVB-B-SEP-002 VFDR QSP16V0508:OPEN:OPEN, SW TO POND WEST HEADER ISOLATION - Simultaneous closure of both Service Water recirculation valves, both to the wet pit and pond, would prevent the establishment of Service Water Train B. Furthermore, interlocks in the valve control circuits prevent the simultaneous opening and closure of both valves. Failure to establish Service Water Train B would pose a challenge to various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2390 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: TBRF - Turbine Building Roof HVAC Room, Units 1 & 2 Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Fire Zone ID Description TBRF1 Turbine Building Roof HVAC Room, Unit 1 TBRF2 Turbine Building Roof HVAC Room, Unit 2 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2391 of 2430 0

Attach~t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3)

                                                                                                                                                                    .0 Fire Area ID:                      TBRF - Turbine Building Roof HVAC Room, Units 1 & 2                                                                          Performance Goals Compliance Basis:                  NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal                                  Method of Accomplishment                                                       Comments 1 Primary Control Station                         Plant shutdown is performed from the Control Room.

2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuringauxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off.Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2392 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: TBRF - Turbine Building Roof HVAC Room, Units 1 & 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal

                                                  " Unit 2: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown.
                                                  " Unit 1: Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown.

6 Process Monitoring " Unit 2: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored.

                                                  " Unit 1: 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/IB/1C pressure is monitored. 6. SG Level - Steam Generator 1A/1B/1C level is monitored.

7.1 Vital Auxiliaries Electrical " Unit 2: 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

                                                  " Unit 1: 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment.

7.2 Vital Auxiliaries Service Water Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries Component Cooling Water Train A/Train B component cooling water is provided with non-essential loads isolated. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2393 of 2430

Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: TBRF - Turbine Building Roof HVAC Room, Units 1 & 2 Performance Goals Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Performance Goal Method of Accomplishment Comments 7.4 Vital Auxiliaries HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service Water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled: therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2394 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: TBRF - Turbine Building Roof HVAC Room, Units 1 & 2 Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
  • The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2395 of 2430 0

0 Attach*it C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: TBRF - Turbine Building Roof HVAC Room, Units 1 & 2 Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required FP System(s)/Feature(s) Description Required By Comments Passive Heat Activated Smoke Vents EEEE/LA Required to support a fire area boundary evaluation. Passive Heat activated Smoke Vents EEEE/LA Required to support a fire area boundary evaluation. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2396 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: TBRF - Turbine Building Roof HVAC Room, Units 1 & 2 Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Title N/A Summary This fire area complies with the deterministic requirements of Section 4.2.3 of NFPA 805. Therefore, a fire risk evaluation is not required. A CDF A LERF DID Maintained Safety Margin Maintained Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2397 of 2430 is 0

Attachit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description C02-RM-U1 C02 Bottle Room (SWIS) SWIS-EXT-U1 SWIS Yard Area Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2398 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room OR Plant shutdown is performed from the Hot Shutdown Panel. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room OR Reactor is manually tripped from the Control Room prior to Control Room evacuation. 2.2 Reactivity Control - Maintain Subcritical Unit 1: Subcritical conditions are maintained by isolating the VCT to prevent Conditions boron dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump or swing charging pump via Train A power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2399 of 2430 0

Attachl, 1t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/1B/1C pressure is monitored. 6. SG Level- Steam Generator 1A/1B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Performance-based approach Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2400 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2401 of 2430 0

AttachO C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-U1 - Yard Area in Vicinity of SWIS Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
  • Elements with construction features equal to 3-hr boundaries were credited as such,
  • The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2402 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Hydrant Suppression YARD-SWIS DID Criteria Required to meet DID criteria. Passive Combustibles and flammable liquid EEEE/LA Required to support a fire area boundary evaluation. control Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2403 of 2430

S Attach. t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area YARD-SWIS-Ul Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions and the installed hydrants, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 6.21 E-08 A LERF 1.19E-10 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the installed hydrants were identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2404 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U1-YARD-SWIS-HVAC-001 VFDR Q1R15AO007:ENERGIZED:ENERGIZED-SUT1B, 4160V SWITCHGEAR BUS 1G - This component, Switchgear 1G, requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to Vital Auxiliaries Electrical Support Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U1-YARD-SWIS-HVAC-002 VFDR Q1R15A0505:ENERGIZED:ENERGIZED, 4160V SWITCHGEAR BUS 1K - This component, Switchgear 1K (SWIS HVAC Room), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U1-YARD-SWIS-HVAC-003 VFDR Q1R42BOO01B:ENERGIZED:ENERGIZED-BC1B, 125V DC BUS 1B - This component, 125V DC Bus 1B (Train B Battery Room Cooler), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID Ul -YARD-SWIS-HVAC-004 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2405 of 2430 S p."

0 Attach~it C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-U1 - Yard Area in Vicinity of SWIS VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q1R42E0002B:AVAILABLE:AVAILABLE, 125V BATTERY lB - This component, Battery 1B (Train B Battery Room Exhaust Fan), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 8(05, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U1-YARD-SWIS-SEP-001 VFDR Q1P16V0539:CLOSED:OPEN, TRAIN A SW EMERGENCY RECIRC TO POND - Fire induced damage to the control circuit in question will only cause the valve to open (actuate relay 71-7X), or defeat the auto-open capability of this function, If there are timing constraints that must be achieved before establishing pond recirc, spurious opening of this valve could occur at an inopportune time, and possible spurious opening of this valve needs to be addressed. Failure to establish recirculation to the pond will prevent the establishment of Service Water Train A, and challenge Vital Auxiliaries Service Water Support Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U1-YARD-SWIS-SEP-002 VFDR Q1P16V'0546:OPEN:OPEN/CLOSED, TRAIN A SW DISCHARGE TO RIVER - The Service water discharge path to the river is not credited in the analysis, however the discharge valve must remain open until recirculation to the pond is established, after which the valve is desired closed. Fire induced cable damage to the cable in this area could result in spurious closure of the valve. Failure to establish Service Water Train A Challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2406 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description C02-RM-U2 C02 Bottle Room (SWIS) SWIS-EXT-U2 SWIS Yard Area Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2407 of 2430 0 O

AttachBit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0-Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump or swing charging pump via Train A power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump or swing charging pump via Train A power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump or swing charging pump via Train A power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers-are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2408 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Performance-based approach Train A service water is provided with two service water pumps in service recirculating to the pond or Train A service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A component cooling water is provided with non-essential loads isolated. Water 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with performance-based approach HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2409 of 2430 0 0

0 Attachlt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) S Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evalup'ions for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2410 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Passive Combustibles and flammable liquid EEEE/LA Required to support a fire area boundary evaluation. control Procedures / Guidance Risk Criteria Improvements to procedures necessary to incorporate recovery actions required to meet risk criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2411 of 2430

                                                                                                                                                                             -10 0

Attach ,tC Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area YARD-SWIS-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the implementation of specified recovery actions, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A COF 2.96E-08 A LERF 4.89E-1 1 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, no additional DID features were identified. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2412 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-YARD-SWIS-HVAC-001 VFDR Q2R42BOO01B:ENERGIZED:ENERGIZED-BC2C, 125V DC BUS 2B - This component, 125V DC Bus 2B (Train B Battery Room Cooler), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that recovery actions(s) are required to meet applicable risk criteria. VFDR ID U2-YARD-SWIS-HVAC-002 VFDR Q2R15A0007:ENERGIZED:ENERGIZED-SUT2A, 4160V SWITCHGEAR BUS 2G - This component, Switchgear 2G (600 V Load Center E Room Cooler), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-YARD-SWIS-HVAC-003 VFDR Q2R42E0002B:AVAILABLE:AVAILABLE, 125V BATTERY 2B - This component, Battery 2B (Train B Battery Room Exhaust Fan), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR not modeled in Fire PRA). VFDR ID U2-YARD-SWIS-HVAC-004 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2413 of 2430 0

Attachet C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR Q2R15A0505:ENERGIZED:ENERGIZED, 4160V SWITCHGEAR BUS 2K - This component, Switchgear 2K (SWIS HVAC Room), requires HVAC support to remain functional. Failure to establish HVAC to support this electrical component will prevent the establishment of all Vital Power. This failure poses a challenge to all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action (VFDR-not modeled in Fire PRA). VFDR ID U2-YARD-SWIS-SEP-001 VFDR Q2P16V0539:CLOSED:OPEN, SW RECIRC TO POND TRAIN A - Fire induced damage to the control circuit in question will only cause the valve to open (actuate relay 71-7X), or defeat the auto-open capability of this function. If there are timing constraints that must be achieved before establishing pond recirc, spurious opening of this valve could occur at an inopportune time, and possible spurious opening of this valve needs to be addressed. Failure to establish recirculation to the pond will prevent the establishment of Service Water Train A, and challenge all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-YARD-SWIS-SEP-002 VFDR Q2P1 6V0546:OPEN:OPEN/CLOSED, TRAIN A SW DISCHARGE TO RIVER - The Service water discharge path to the river is not credited in the analysis, however the discharge valve must remain open until recirculation to the pond is established, after which the valve is desired closed. Fire induced cable damage to the cable in this area could result in spurious closure of the valve. Failure to establish Service Water Train A Challenges various Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2414 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-Ul - Yard Area in Main Power Block Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 1-CST-PT-U1 Access Hatch Room to CST Pipe Trench 1-SWSURTK-U1 Service Water Surge Tank 2-CST-PT-U1 Aux Building to CST Pipe Trench 2-RWST-PT-U1 Aux Building to RWST Pipe Trench 2-SWSURTK-U1 Service Water Surge Tank FOST-Ul Fuel Oil Storage Tank HV-SWYD-U1 High Voltage Switchyard OUTSIDE-Ul1 General Outside Locations in Main Power Block UNGND-U1 Underground Ductbanks Between Various Structures Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2415 of 2430 S

Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) 0 Fire Area ID: YARD-Ul - Yard Area in Main Power Block Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, a letdown isolation Paths valve, or a letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A PORV, Train B Control PORV or aux spray for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2416 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-Ul - Yard Area in Main Power Block Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump and TDAFW pump supplying Steam Generator 1A/1B/1C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, and RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 1A/ B/1 C pressure is monitored. 6. SG Level - Steam Generator 1A/i B/1C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Performance-based approach electrical power is supplied by off-site power via SUT 1A/SUT 1B, diesel generator EDG1-2A/EDG-1B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B-equipment. 7.2 Vital Auxiliaries - Service Water Performace-based approach Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2417 of 2430

SAttacht CI Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-Ul - Yard Area in Main Power Block Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2418 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-Ul - Yard Area in Main Power Block Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Passive Administrative Control of Vehicles EEEE/LA Required to support a fire area boundary evaluation. Passive Combustibles and flammable liquid EEEE/LA Required to support a fire area boundary evaluation. control Passive Restricted transient controls DID Criteria Required to meet DID criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2419 of 2430

Attachigit C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-Ul - Yard Area in Main Power Block Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area YARD-Ul Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the procedure enhancements to limit transients, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 5.70E-08 A LERF 2.03E-10 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the procedure enhancements to limit transients were identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2420 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-Ul - Yard Area in Main Power Block VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U1-YARD-SEP-001 VFDR Q1P16V0545:OPEN:OPEN/CLOSED, TRAIN B SW DISCHARGE TO RIVER - Service water discharge to the river must be isolated and recirculation to the Pond must be established in order to ensure the availability of service water. This valve must remain open initially until recirculation to the pond is established. Fire induced circuit failure could spuriously close this valve in the meantime. Failure to establish a recirculation path for service water challenges all Nuclear Safety Performance Criterion. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U1-YARD-SEP-002 VFDR Q1P16V0546:OPEN:OPEN/CLOSED, TRAIN A SW DISCHARGE TO RIVER - The Service water discharge path to the river is not credited in the analysis, however the discharge valve must remain open until recirculation to the pond is established, after which the valve is desired closed. Fire induced cable damage to the cable in this area could result in spurious closure of the valve. Failure to establish Train A Service Water Challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U1-YARD-SEP-003 VFDR Q1Y52P0502A:OFF:ON, 1B DG FUEL OIL MANUAL TRANSFER PUMP - The EDG 1B Fuel Oil Pump is required to support EDG 1B functionality. Offsite power supplies are not available for a fire in the YARD, hence the diesel generator must be relied upon to provide Electrical Power. Fire induced circuit failure to the Fuel Oil Pump P0502A or P0502B (the manual and automatic transfer pumps) will prevent availability of the EDG 1B Fuel Oil. Failure to establish vital AC Electrical power challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U1-YARD-SEP-004 Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2421 of 2430

0 Attach*t C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-Ul - Yard Area in Main Power Block VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR QSY52PO501A:OFF:ON, 1-2A DG FUEL OIL AUTO TRANSFER PUMP - The EDG 1-2A Fuel Oil Pump is required to support EDG 1-2A functionality. Offsite power supplies are not available for a fire in the YARD, hence the diesel generator must be relied upon to provide Electrical Power. Fire induced circuit failure to the Fuel Oil Pump P0501A or P0501 B (the manual and automatic transfer pumps) will prevent availability of the EDG 1 B Fuel Oil. Failure to establish vital AC Electrical power challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2422 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-U2 - Yard Area in Main Power Block. Fire Area Definition Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Fire Zone ID Description 1-CST-PT-U2 Access Hatch Room to CST Pipe Trench 1-SWSURTK-U2 Service Water Surge Tank 2-CST-PT-U2 Aux Building to CST Pipe Trench 2-RWST-PT-U2 Aux Building to RWST Pipe Trench 2-SWSURTK-U2 Service Water Surge Tank FOST-U2 Fuel Oil Storage Tank HV-SWYD-U2 High Voltage Switchyard OUTSIDE-U2 General Outside Locations in Main Power Block UNGND-U2 Underground Ductbanks Between Various Structures Fire Safety Analysis Data Manager (4. 1 ) Farley Run: 08/18/2012 22:12 Page: 2423 of 2430

  • Attacht C 0 Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3)

Fire Area ID: YARD-U2 - Yard Area in Main Power Block Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 1 Primary Control Station Plant shutdown is performed from the Control Room. 2.1 Reactivity Control - Reactor Trip Reactor is manually tripped from the Control Room. 2.2 Reactivity Control - Maintain Subcritical Subcritical conditions are maintained by isolating the VCT to prevent boron Conditions dilution and by charging borated water from the RWST using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power. 3.1 RCS Inventory Control - RCS Makeup RCS inventory is controlled using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power aligned to the RWST. 3.2 RCS Inventory Control - Isolate Leakage Normal letdown is isolated using orifice isolation valves, letdown isolation Paths valve or letdown path containment isolation valve. Excess letdown is isolated using one or more excess letdown or containment isolation valves. PZR PORV leakage paths are isolated using Train A PORV and Train B PORV. The RCS to RHR high/low pressure interface is isolated using the Train A/Train B RHR inboard isolation valve and Train A/Train B RHR outboard isolation valve. 3.3 RCS Inventory Control - RCP Seal Integrity Maintain RCP Seal Integrity - RCP seal integrity is maintained by tripping all RCPs, maintaining normal seal injection using Train A charging pump, Train B charging pump or swing charging pump via Train A/Train B power, and preventing failure of the RCP thermal barriers. RCP seal injection paths are secured by isolating the supply and discharge seal injection lines. CCW to RCP thermal barriers are isolated using containment isolation valves or the CCW to RCP thermal barrier isolation valve. 4.1 RCS Pressure Control - Pressure Transient Undesired depressurization due to inadvertent spray is prevented by ensuring auxiliary spray valve remains closed and the Loop 1 and Loop 2 RCPs are shut off. Undesired pressure increase is prevented by deenergizing all pressurizer heater groups. 4.2 RCS Pressure Control - Positive Pressure Positive control of RCS pressure is accomplished with Train A/Train B PORV Control or aux spray-for pressure reduction and Pressurizer Heater Group A/B for pressure increase. Fire Safety Analysis Data Manager (4-1) Farley Run: 08/18/2012 22:12 Page: 2424 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-U2 - Yard Area in Main Power Block Performance Goals Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments 5 Decay Heat Removal Decay heat removal during HSD is accomplished using Train A MDAFW pump, Train B MDAFW pump or TDAFW pump supplying Steam Generator 2A/2B/2C. Main feed is isolated to prevent uncontrolled cooldown. 6 Process Monitoring 1. Shutdown Margin - Shutdown margin is monitored by source range detector Ch 1/Ch 2. 2. RCS Pressure - RCS pressure is monitored by PZR narrow range Ch 1/Ch 2/Ch 3, PZR non-safety channel, RCS wide range pressure for Loop 1/Loop 3. 3. Pressurizer Level - Pressurizer level is monitored by PZR level Ch 1/Ch 2/Ch 3. 4. RCS Temperature - RCS Loop 1/Loop 2/Loop 3 temperature is monitored by loop hot and cold leg RTDs. 5. SG Pressure - Steam Generator 2A/2B/2C pressure is monitored. 6. SG Level - Steam Generator 2A/2B/2C level is monitored. 7.1 Vital Auxiliaries - Electrical 1. Performance-based approach electrical power is supplied by off-site power via SUT 2A/SUT 2B, diesel generator EDG1-2A/EDG-2B. 2. 4.16 kV and 600 V power is supplied by Train A/Train B distribution equipment. 3. 125 VDC power and 120 VAC power is supplied by Train A/Train B equipment. 7.2 Vital Auxiliaries - Service Water Performance-based approach Train A/Train B service water is provided with two service water pumps in service recirculating to the pond or Train A/Train B service water is provided with one service water pump in service recirculating to the pond and non-essential turbine building loads isolated. 7.3 Vital Auxiliaries - Component Cooling Train A/Train B component cooling water is provided with non-essential loads Water isolated. 7.4 Vital Auxiliaries - HVAC Control Room cooling is provided by Train A/Train B HVAC. Room cooling at essential locations is provided with HVAC equipment corresponding to the service water train. Fire Suppression Activities Effect on Nuclear Safety Performance Criteria Safe and stable conditions can be achieved and maintained utilizing equipment and cables outside of the area of fire suppression activity. No automatic suppression is installed in this area. Discharge of manual suppression water to adjacent compartments is controlled; therefore, fire suppression activities will not adversely affect the plant's ability to achieve the nuclear safety performance criteria. Fire Safety Analysis Data Manager (4. 1) Farley Run: 08/18/2012 22:12 Page: 2425 of 2430

  • Attach& 0, Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3)

Fire Area ID: YARD-U2 - Yard Area in Main Power Block Engineering Evaluations Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Engineering Evaluation ID SM-C051326701-006 Identify Regulatory Fire Barriers Revision 3 Inactive No Functionally Equivalent No Adequate for the Hazard Yes

                                                                                                                                       .1 Summary

Purpose:

This report includes engineering equivalency evaluations for several fire area boundaries in Units 1 and 2 power block buildings, as well as the shared areas such as SWIS, RWIS and the Diesel Generator Building. The approach was to examine any boundary for which there was not a documented/credited 3-hr rated barrier. Evaluations were also included non-rated reach rod penetrations and separation between pressure sensing lines. Bases for Acceptability:

                                " The fire areas, fire zones and rooms on both sides of the barrier were identified,
                                " The construction of the boundary and the potential issue with the element in question was described,
                                " The fire hazards and fire protection features on both sides of the barrier were described,
                                " Elements with construction features equal to 3-hr boundaries were credited as such,
                                " The evaluation demonstrates that elements with construction features not equivalent to 3-hr rated boundaries are adequate for the hazard.

Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2426 of 2430

Attachment C Table C-I NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-U2 - Yard Area in Main Power Block Required Fire Protection Systems and Features Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required FP System(s)/Feature(s) Description Required By Comments Passive Administrative Control of Vehicles EEEE/LA Required to support a fire area boundary evaluation. Passive Combustibles and flammable liquid EEEE/LA Required for a fire area boundary evalulation. control Passive Restricted transient controls DID Criteria Required to meet DID criteria. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2427 of 2430 0 0

Attachit C i Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-U2 - Yard Area in Main Power Block Fire Risk Evaluation Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Title FRE for Fire Area YARD-U2 Summary A risk-informed, performance-based fire risk evaluation was performed for the fire area to address the variances from the deterministic requirements (VFDRs) of NFPA 805 Section 4.2.3. The acceptability of these VFDRs is based on the measured change in CDF and LERF and the maintenance of defense in depth and safety margins. The fire risk evaluation determined that with the procedure enhancements to limit transients, the applicable risk, defense-in-depth, and safety margin criteria were satisfied. A CDF 7.80E-08 A LERF 2.63E-10 DID Maintained The VFDRs and the associated Fire Area risk (CDF) and scenario consequences (CCDP values) were evaluated to identify general DID echelon imbalances. Potential methods to balance the DID features were identified ensuring an adequate balance of DID features is maintained for the Fire Area. As a result of the FRE for this area, the procedure enhancements to limit transients were identified as required for DID. Safety Margin Maintained All analyses and assessment have been performed utilizing accepted techniques and industry accepted standards. In addition, safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) have been considered and provides sufficient margin to account for analysis and data uncertainty. As such, the Safety Margins are maintained. Comments Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2428 of 2430

Attachment C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-U2 - Yard Area in Main Power Block VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-YARD-ASSO-001 VFDR Q1R16B0509:ENERGIZED:ENERGIZED-U2, 600V LOAD CENTER 1S/2S - MCC 1P is required to support the Service Water Recirculation valve, which must open in order to establish the Service water Pond lineup. A fault on the cited cable concurrent with a loss of control power to the associated load breaker could result in a loss of power to Load Center 1S/2S which supplies MCC 1P. Failure to establish Service Water Train B in this area challenges the establishment of Train B AC power and poses a challenge to various Nuclear Safety Performance Goals. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-YARD-SEP-001 VFDR Q2P16V0546:OPEN:OPEN/CLOSED, TRAIN A SW DISCHARGE TO RIVER - Service water discharge to the river needs to remain available initially before the pond recirculation alignment is established. Valve Q2P16V0546 is required open initially and must close in order isolate the river supply, once recirculation to the pond has been established. Fire induced control circuit damage to the cited circuit could prevent operation of the valve from the control room or cause the valve to spuriously operate. This failure challenges the establishment of Service Water and challenges all Nuclear Safety Performance Goals. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-YARD-SEP-002 VFDR N2F16LI4075A:AVAILABLE:AVAILABLE, RWST LEVEL INDICATOR LI-4075A - The RWST is the credited source of suction for charging. RWST level instrumentation is required to monitor the RWST level to ensure that adequate amounts of charging inventory are available for use. Fire induced control circuit damage to instruments Q2F16LT0501 or Q2F16LT0502 could render the RWST level instrumentation unavailable, or lead to erroneous indication. Failure to ensure availability of RWST Instrumentation challenges the RCS Inventory Control Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2429 of 2430 0

0 Attachtt C Table C-1 NFPA 805 Ch 4 Compliance (NEI 04-02 Table B-3) Fire Area ID: YARD-U2 - Yard Area in Main Power Block VFDRs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions VFDR ID U2-YARD-SEP-003 VFDR Q2Y52P0503B:OFF:ON, 2B DG FUEL OIL AUTO TRANSFER PUMP - The EDG 2B Fuel Oil Pump is required to support EDG 2B functionality. Offsite power supplies are not available for a fire in the YARD, hence the diesel generator must be relied upon to provide Electrical Power. Fire induced circuit failure to the Fuel Oil Pump P0502A or P0502B (the manual and automatic transfer pumps) will prevent availability of the EDG 2B Fuel Oil. Failure to establish vital AC Electrical power challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. VFDR ID U2-YARD-SEP-004 VFDR QSY52PO501A:OFF:ON, 1-2A DG FUEL OIL AUTO TRANSFER PUMP - The EDG 1-2A Fuel Oil Pump is required to support EDG 1-2A functionality. Offsite power supplies are not available for a fire in the YARD, hence the diesel generator must be relied upon to provide Electrical Power. Fire induced circuit failure to the Fuel Oil Pump P0501A or P05018 (the manual and automatic transfer pumps) will prevent availability of the EDG 1-2A Fuel Oil. Failure to establish vital AC Electrical power challenges all Nuclear Safety Performance Criteria. This condition represents a variance from the deterministic requirements of Section 4.2.3 of NFPA 805. This is a Separation Issue. Evaluate for compliance using the performance-based approach of NFPA 805, Section 4.2.4. Disposition This condition was evaluated for compliance using the performance-based approach of NFPA 805, Section 4.2.4. A fire risk evaluation determined that applicable risk, defense-in-depth, and safety margin criteria were satisfied without further action. Fire Safety Analysis Data Manager (4.1) Farley Run: 08/18/2012 22:12 Page: 2430 of 2430

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 044-Ul - Control Room Complex & TSC Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D (All) Area Wide None None R, D Modifications: R D 0401-U1 401 Control Room None D None Detection System, 1A-54: D 0412-Ul 412 Kitchen None D None Detection System, 1A-1 17: D 0413-Ul 413 Kitchen store None D None Detection System, 1A-117: D 0414-Ul 414 Toilet None None None None 0416-Ul 416 Unit 1 Instrument Rack Area None D None Detection System, 1A-54: D 0471-Ul 471 Unit 2 Instrument Rack Area None D None Detection System, 1A-54: D 0472-U1 472 Control Room Supply None D None Detection System, 1A- 117: D 0474-Ul 474 Office None None None None 0476-Ul 476 Offices None None None None 2453-Ul 2453 Technical Support Center None D None Detection System, 2A-51: D 2454-U1 2454 Technical Support Center None D None Detection System, 2A-200: D Detection System, 2A-51: D 2455-U1 2455 Technical Support Center None D None Detection System, 2A-200: D Detection System, 2A-51: D Fire Area ID: 044-U2 - Control Room Complex & TSC Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D (All) Area Wide None None R, D Modifications: R D 0401-U2 401 Control Room None D None Detection System, 1A-54: D 0412-U2 412 Kitchen None D None Detection System, 1A-117: D 0413-U2 413 Kitchen store None D None Detection System, 1A-1 17: D 0414-U2 414 Toilet None None None None 0416-U2 416 Unit 1 Instrument Rack Area None D None Detection System, 1A-54: D 0471-U2 471 Unit 2 Instrument Rack Area None D None Detection System, 1A-54: D 0472-U2 472 Control Room Supply None D None Detection System, 1A-1 17: D 0474-U2 474 Office None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 1 of 104

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection.Systems and Features 0 Fire Area ID: 044-U2 - Control Room Complex & TSC Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0476-U2 476 Offices None None None None 2453-U2 2453 Technical Support Center None D None Detection System, 2A-51: D 2454-U2 2454 Technical Support Center None D None Detection System, 2A-200: D Detection System, 2A-51: D 2455-U2 2455 Technical Support Center None D None Detection System, 2A-200: D Detection System, 2A-51: D Fire Area ID: 051-Ul - Control Room HVAC Equipment Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0501-Ul 501 Control Room HVAC None D None Detection System, 1A- 110: D Equipment Room Detection System, 2A- 110: D 2501-Ul 2501 Control Room HVAC None D None Detection System, 2A- 110: D Equipment Room Fire Area ID: 051 -U2 - Control Room HVAC Equipment Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0501 -U2 501 Control Room HVAC None D None Detection System, 1A-110: D Equipment Room Detection System, 2A- 110: D 2501-U2 2501 Control Room HVAC None D None Detection System, 2A-110: D Equipment Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 2 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 056A-U1 - DG Building Switchgear Room Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R DGB-56A-U1 DG Building Switchgear Room E, R E, R, D E Detection System, 1D-115: E R D Train A Detection System, 1D-80: E R D Detection System, 2D-80: E R D Gaseous Suppression, 1D-80: E R Gaseous Suppression, 2D-80: E R Restricted transient controls: E Fire Area ID: 056A-U2 - DG Building Switchgear Room Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R DGB-56A-U2 DG Building Switchgear Room E, R, D E, R, D E Detection System, 1D-115: E R D Train A Detection System, 1D-80: E R D Detection System, 2D-80: E R D Gaseous Suppression, 1D-80: E R D Gaseous Suppression, 2D-80: E R D Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 3 of 104

Attachl tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 056B-U1 - DG Building Switchgear Room Train B & Foyer Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R DGB-56B-U1 DG Building Switchgear Room E, R, D E, R, D E Detection System, 1D-115: E R D Train B Detection System, 1D-81: E R D Detection System, 2D-81: E R D Gaseous Suppression, 1 D-81: E R D Gaseous Suppression, 2D-81: E R D Restricted transient controls: E DGB-FOY-Ul DG Building Foyer None E, R, D None Detection System, 1D-115: E R D Fire Area ID: 056B-U2 - DG Building Switchgear Room Train B & Foyer Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R DGB-56B-U2 DG Building Switchgear Room E, R, D E, R, D E Detection System, 1D-115: E R D Train B Detection System, 1D-81: E R D Detection System, 2D-81: E R D Gaseous Suppression, 1D-81: E R D Gaseous Suppression, 2D-81: E R D Restricted transient controls: E DGB-FOY-U2 DG Building Foyer None R, D None Detection System, 1D-115: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 4 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 057-Ul - Diesel Generator Room 2C Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions. Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R DGB-2C-U1 Diesel Generator Room 2C E, R E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R Restricted transient controls: E Fire Area ID: 057-U2 - Diesel Generator Room 2C Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R DGB-2C-U2 Diesel Generator Room 2C E, R E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R Restricted transient controls: E Fire Area ID: 058-U1 - Diesel Generator Room 1B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R DGB-IB-U1 Diesel Generator Room 1B E, R, D E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R D Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 5 of 104

Attachft C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 058-U2 - Diesel Generator Room 1B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with.simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R DGB-1B-U2 Diesel Generator Room 1B E, R, D E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R D Restricted transient controls: E Fire Area ID: 059-Ul - Diesel Generator Room 2B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R DGB-2B-U1 Diesel Generator Room 2B E, R E, R E Detection System, 1D-78: E R Gaseous Suppression, 1D-78: E R Restricted transient controls: E Fire Area ID: 059-U2 - Diesel Generator Room 2B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R DGB-2B-U2 Diesel Generator Room 2B E, R, D E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R D Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 6 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 060-U1 - Diesel Generator Room 1C Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R DGB-1C-U1 Diesel Generator Room 1C E, R E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R Restricted transient controls: E Fire Area ID: 060-U2 - Diesel Generator Room 1C Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R DGB-1C-U2 Diesel Generator Room 1C E, R E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R Restricted transient controls: E Fire Area ID: 061-Ul - Diesel Generator Room 1-2A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R DGB-1-2A-U1 Diesel Generator Room 1-2A E, R, D E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1D-78: E R D Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 7 of 104

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 061-U2 - Diesel Generator Room 1-2A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R DGB-1-2A-U2 Diesel Generator Room 1-2A E, R E, R, D E Detection System, 1D-78: E R D Gaseous Suppression, 1 D-78: E R Restricted transient controls: E Fire Area ID: 062 - Day Ftiel Tank Room 2C Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DGB-DFT-2C Day Fuel Tank Room 2C E E E Detection System, 1D-79: E Gaseous Suppression, 1D-79: E Restricted transient controls: E Fire Area ID: 063 - Day Fuel Tank Room 1B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DGB-DFT-1B Day Fuel Tank Room 1B E E E Detection System, 1D-79: E Gaseous Suppression, 1D-79: E Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 8 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 064 - Day Fuel Tank Room 2B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DGB-DFT-2B Day Fuel Tank Room 2B E E E Detection System, 1D-79: E Gaseous Suppression, 1D-79: E Restricted transient controls: E Fire Area ID: 065 - Day Fuel Tank Room 1C Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DGB-DFT-1C Day Fuel Tank Room 1C E E E Detection System, 1D-79: E Gaseous Suppression, 1 D-79: E Restricted transient controls: E Fire Area ID: 066 - Day Fuel Tank Room 1-2A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DGB-DFT-1-2A Day Fuel Tank Room 1-2A E E E Detection System, 1D-79: E Gaseous Suppression, 1D-79: E Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 9 of 104

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems-and Features 0 Fire Area ID: 067 - RWIS Pump Room B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details RWIS-PR-B RWIS Pump Room B None None None None Fire Area ID: 068 - RWIS Pump Room A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details RWIS-PR-A RWIS Pump Room A None None None None Fire Area ID: 069 - RWIS Switchgear Room-Train B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details RWIS-SG-B RWIS Switchgear Room-Train B None None None None Fire Area ID: 070 - RWIS Switchgear Room-Train A Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details RWIS-SG-A RWIS Switchgear Room-Train A None R, D None Detection System, 1RW-96: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 10 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 071 - DG Building Corridor Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DGB-COR DG Building Corridor None E E Detection System, 1D-116: E Restricted transient controls: E Fire Area ID: 072-Ul - Service Water Pump Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R SWIS-72A-U1 Service Water Pump Room None None None None SWIS-72B-U1 Service Water Pump Room None None None None SWIS-72C-U1 Service Water Pump Room None None None None SWIS-72D-U1 Service Water Pump Room None None None None SWIS-72E-U1 Service Water Pump Room None None None None SWIS-PR-U1 Service Water Pump Room R, D R, D None Detection System, 1SW-111: R D Detection System, 1SW-111A: R D Detection System, 1SW-111 B: R D Water Suppression, 1SW-111: R D Water Suppression, 1SW-111A: R D Water Suppression, 1SW-111 B: R D Fire Area ID: 072-U2 - Service Water Pump Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R SWIS-72A-U2 Service Water Pump Room None None None None SWIS-72B-U2 Service Water Pump Room None None None None SWIS-72C-U2 Service Water Pump Room None None None None SWIS-72D-U2 Service Water Pump Room None None None None SWIS-72E-U2 Service Water Pump Room None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 11 of 104 0 0

Attachoit C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 072-U2 - Service Water Pump Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWIS-PR-U2 Service Water Pump Room R, D R, D None Detection System, 1SW-I11: R D Detection System, 1SW-111 A: R D Detection System, 1SW-111 B: R D Water Suppression, 1SW-111: R D Water Suppression, 1SW-111A: R D Water Suppression, 1SW-111 B: R D Fire Area ID: 073 - SWIS Battery Room-Train B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWIS-BAT-B SWIS Battery Room-Train B None E E Detection System, 1SW-97: E Restricted transient controls: E Fire Area ID: 074 - SWIS Battery Room-Train A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWIS-BAT-A SWIS Battery Room-Train A None E E Detection System, 1SW-97: E Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 12 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 075-U1 - SWIS 5 kV Switchgear Room B & West Stairs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R SWIS-SG-B-U1 SWIS 5 kV Disconnect Switch E, R E, R, D E Detection System, 1SW-97: E R D Train B, Switchgear Room B Gaseous Suppression, 1SW-99: E R Gaseous Suppression, 2SW-99: E R Restricted transient controls: E SWIS-STAIR-W-U1 SWIS West Stairwell None R, D None Detection System, 1SW-97: R D Fire Area ID: 075-U2 - SWIS 5 kV Switchgear Room B & West Stairs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R SWIS-SG-B-U2 SWIS 5 kV Disconnect Switch E, R, D E, R, D E Detection System, 1SW-97: E R D Train B, Switchgear Room B Gaseous Suppression, 1SW-99: E R D Gaseous Suppression, 2SW-99: E R D Restricted transient controls: E SWIS-STAIR-W-U2 SWIS West Stairwell None R, D None Detection System, 1SW-97: R D Fire Area ID: 076-Ul - SWIS 5 kV Switchgear Room A & East Stairs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWIS-SG-A-U1 SWIS 5 kV Disconnect Switch E, R E, R, D E Detection System, 1SW-97: E R D Train A, Switchgear Room A Gaseous Suppression, 1SW-99: E R Gaseous Suppression, 2SW-99: E R Restricted transient controls: E SWIS-STAIR-E-Ul SWIS East Stairwell None R, D None Detection System, 1SW-97: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 13 of 104 0

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 076-U2 - SWIS 5 kV Switchgear Room A & East Stairs Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R SWIS-SG-A-U2 SWIS 5 kV Disconnect Switch E, R, D E, R, D E Detection System, 1SW-97: E R D Train A, Switchgear Room A Gaseous Suppression, 1SW-99: E R D Gaseous Suppression, 2SW-99: E R D Restricted transient controls: E SWIS-STAIR-E-U2 SWIS East Stairwell None R, D None Detection System, 1SW-97: R D Fire Area ID: 093 - Aux Building Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0601 Drumming Area/Combustible None None None None Storage Room 0602 Passageway/Combustible None None None None Storage Room 0603 Drum Storage Area/Combustible None None None None Storage Room 2601 Drumming Area/Combustible None None None None Storage Room 2602 Passageway/Combustible E E E Detection System, 1A-134: E Storage Room Restricted transient controls: E Water Suppression, 1A-134: E 2603 Drum Storage Area/Combustible None None None None Storage Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 14 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-001 - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0101 101 Waste Gas Decay Tank None R None Detection System, 1A-132: R Room 0102 102 Valve Compartment Room None R None Detection System, 1A-132: R 0103 103 Corridor None E, R E Detection System, 1A-132: E R Restricted transient controls: E 0104 104 Passageway to Unit 2 None E, R E Detection System, 1A-132: E R Plant staff Training: E Restricted transient controls: E 0105 105 Catalytic H2 Recombiner 1A None R None Detection System, 1A-132: R Room 0106 106 Catalytic H2 Recombiner 1B None R None Detection System, 1A-132: R Room 0108 108 Waste Monitor Tank Room None R None Detection System, 1A-100: R 0109 109 Waste Monitor Tank Pump None R None Detection System, 1A-100: R Room 0110 110 Monitor Control Panel Room None R None Detection System, 1A-100: R 0111 111 Containment Spray Pump None R None Detection System, 1A-100: R Room 1A 0112 112 Access to Tendon Access None None None None Gallery 0113 113 Valve Encapsulation None R None Detection System, 1A-100: R 0114 114 Pipe Chase None None None None 0115 115 Hallway None None E Restricted transient controls: E 0118 118 Floor Drain Tank Room None R None Detection System, 1A-100: R 0119 119 Waste Holdup Tank Room None R None Detection System, 1A-100: R 0120 120 Corridor None R None Detection System, 1A-100: R 0121 121 Floor Drain Tank Pump None R None Detection System, 1A-100: R Room 0122 122 Waste Evaporator Feed None R None Detection System, 1A-100: R Pump Room 0123 123 Pipe Chase None None None None 0124 124 Valve Encapsulation None R None Detection System, 1A-100: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 15 of 104 0

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 1-001 - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0125 125 Containment Spray Pump None E, R, D None Detection System, 1A-100: E R D Room 1B 0126 126 Pipe Chase None None None None 0127 127 Pipe Chase None None None None 0128 128 RHR Heat Exchanger Room None R None Detection System, 1A-100: R 0129 129 RHR Low Head Pump Room None R, D None Detection System, 1A-100: R D 0130 130 Pipe Chase None None None None 0131 131 RHR Low Head Pump Room None R, D None Detection System, 1A-100: R D 0169 169 Duct and Pipe Chase None None None None 0183 183 Tendon Access Gallery None E, R, D E, D Detection System, 1A-101: E R D Entrance Restricted transient controls: E D 0184 184 Piping Penetration Room, El. None R, D None Detection System, 1A-102: R D 100,-0", 0196 196 Access to Tendon Access None None None None Gallery 0223 223 Piping Penetration Room, El. None R None Detection System, 1A-45: R 121'-0" Fire Area ID: 1-004-Ul - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0140-U1 140 Waste Gas Decay Tank None None None None Drain Filter Room 0151-U1 151 Waste Gas Decay Tank None R None Detection System, 1A-102: R Rooms 0152-U1 152 Valve Compartment Room None R None Detection System, 1A-102: R 0153-U1 153 Waste Gas Compressor None R None Detection System, 1A-102: R Room 0154-U1 154 Waste Evaporator Steam None R None Detection System, 1A-102: R Generator Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 16 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-U1 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0154A-U1 154A Valve Compartment Room None R None Detection System, 1A-102: R 0155-U1 155 Passageway to Unit 2(1) None None E Restricted transient controls: E 0156-U1 156 Holdup Tank Room None None None None 0157-U1 157 Holdup Tank Room None None None None 0158-U1 158 Holdup Tank Room None None None None 0159-U1 159 Recycle Evaporator Feed None None None None Pump Room 0160-U1 160 Hatch Area None R None Detection System, 1A-118: R 0161-U1 161 Corridor E, R, D E, R, D E Detection System, 1A-118: E R D Restricted transient controls: E Water Suppression, 1A-1 18: E R D 0162-U1 162 Hallway E, R, D E, R, D E, D Detection System, 1A-25: E R D Restricted transient controls: E D Water Suppression, 1A-25: E R D 0163-U1 163 WDS Control Panel Room E, R, D E, R, D None Detection System, 1A-25: E R D Water Suppression, 1A-25: E R D 0164-U1 164 Laundry and Hot Shower R, D R, D None Detection System, 1A-25: R D Tank Room/Storage Room Water Suppression, 1A-25: R D 0165-U1 165 Waste Gas Decay Tank None R None Detection System, 1A-102: R Room 0166-U1 166 Waste Gas Decay Tank None R None Detection System, 1A-102: R Room 0168-U1 168 Chemical and Laundry Drain R, D R, D D Detection System, 1A-25: R D Tank Room Restricted transient controls: D Water Suppression, 1A-25: R D 0170-Ul 170 Letdown Heat Exchanger None E, R None Detection System, 1A-101: E R Room 0175-U1 175 Hallway E, R E, R None Detection System, 1A-118: E R Water Suppression, 1A-118: E R 0176-U1 176 Secondary Spent-Resin None None None None Storage Tank Room 0177-U1 177 Pump Room None E, R None Detection System, 1A- 101: E R 0178-U1 178 Filter Room None R None Detection System, 1A-101: R 0180-U1 180 Recycle Evaporator Steam None R None Detection System, 1A-101: R Generator Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 17 of 104

Attach nt C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems, and Features Fire Area ID: 1-004-U1 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0186-Ul 186 Boric Acid Area R R None Detection System, 1A-1 18: R Water Suppression, 1A-118: R 0187-Ul 187 Hydro Test Pump Room None R None Detection System, 1A-101: R 0188-U1 188 Boric Acid Tank Area None R None Detection System, 1A-103: R 0203-U1 203 Waste Condenser Tanks and None R None Detection System, 1A-104: R Pump Room 0204-U1 204 Waste Evaporator Package None R None Detection System, 1A-104: R Room 0205-U1 205 Passageway to Unit 2 None E, R E Detection System, 1A-35: E R Restricted transient controls: E 0206-U1 206 Heat Exchanger Room None R None Detection System, 1A-104: R 0207-U1 207 Hatch Area E, R E, R E Detection System, 1A-35: E R Restricted transient controls: E Water Suppression, 1A-130: E R 0208-U1 208 Corridor E, R, D E, R, D E Detection System, 1A-35: E R D Restricted transient controls: E Water Suppression, 1A-35: E R D 0209-U1 209 Hallway R R None Detection System, 1A-35: R Water Suppression, 1A-35: R 0215-U1 215 Duct and Pipe Chase None None None None 0216-Ul 216 Valve Compartments Area None R None Detection System, 1A-103: R 0217-U1 217 Volume Control Tank Room None None None None 0218-Ul 218 Chiller Unit Room None None None None 0219-U1 219 Pipe Chase None None None None 0220-U1 220 Valve Compartment Room None R None Detection System, 1A-103: R 0221-U1 221 Primary Spent-Resin Storage None None None None Tank Room 0222-U1 222 Corridor R R None Detection System, 1A-35: R Water Suppression, 1A-35: R 0230-U1 230 Recycle Evaporator Package None R None Detection System, 1A-103: R Room 0231-Ul 231 Sluice Pump Room None R None Detection System, 1A-103: R 0232-U1 232 Sluice Filter Room None R None Detection System, 1A-103: R 0236-U1 236 Duct Chase None None None None 0237-Ul 237 Corridor None R None Detection System, 1A-103: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 18 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-Ul - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0238-U1 238 Cask Storage Area None R None Detection System, 1A-103: R Detection System, 1A-107: R 0239-U1 239 Transfer Canal None R None Detection System, 1A-107: R 0240-Ul 240 Spent-Fuel Pool Room None R None Detection System, 1A-107: R 0253-U1 253 Valve Compartment None None None None 0301-Ul 301 Seal Water Filter Room None R None Detection System, 1A-105: R 0302-U1 302 Recycle Evaporator Feed None R None Detection System, 1A-105: R Filter Room 0303-U1 303 Reactor Coolant Filter Room None R None Detection System, 1A-105: R 0304-U1 304 Waste Monitor None R None Detection System, 1A-105: R 0305-U1 305 Seal Injection Filter Room None R None Detection System, 1A-105: R 0306-U1 306 Recycle Evaporator Feed None None None None Demineralizer Room 0307-U1 307 Valve Compartment Room None R None Detection System, 1A-105: R 0308-U1 308 Waste Condensate and None None None None Monitor Tank Demineralizer Room 0309-U1 309 Hatch Area None E, R E Detection System, 1A-105: E R Restricted transient controls: E 0310-Ul 310 Valve Compartment Room None R None Detection System, 1A-105: R 031 1-Ul 311 Recycle Evaporator None R None Detection System, 1A-105: R Concentrates Filter Room 0312-U1 312 Corridor R R None Detection System, 1A-105: R Detection System, 1A-48: R Water Suppression, 1A-48: R 0313-Ul 313 Floor Drain and Laundry None R None Detection System, 1A-105: R Tank Filter Room 0314-U1 314 Waste Evaporator Feed Filter None R None Detection System, 1A-105: R Room 0315-Ul 315 Recycle Waste Condenser None R None Detection System, 1A-105: R Filter Room 0316-U1 316 Passageway to Unit 2 R E, R E Detection System, 1A-48: E R Restricted transient controls: E Water Suppression, 1A-48: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 19 of 104

Attach ,tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-Ul - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0322-Ul 322 Hallway E, R E, R E Detection System, 1A-48: E R Restricted transient controls: E Water Suppression, 1A-48: E R 0323-U1 323 Sample Room None R None Detection System, 1A-49: R 0324-U1 324 Primary-Chemistry Lab None R None Detection System, 1A-49: R 0325-U1 325 Counting Room/Spectro- None R None Detection System, 1A-49: R photometer Lab 0326-U1 326 Radiochemistry Lab None R None Detection System, 1A-49: R 0327-U1 327 Valve Access Area None None None None 0328-U1 328 BTR Demineralizer Room None None None None 0329-U1 329 Pipe Tunnel None R None Detection System, 1A-105: R Detection System, 1A-107: R 0330-U1 330 Chiller Surge Tanks Pump None R None Detection System, 1A-48: R Room 0331-U1 331 Valve Access Area None R None Detection System, 1A-48: R 0332-U1 332 MCC 1A/2A Area None R None Detection System, 1A-48: R 0340-U1 340 Demineralizer Compartment None None None None 0341-Ul 341 Pipe Chase None None None None 0342-U1 342 Spent-Fuel Pool Pump Room None R None Detection System, 1A-48: R 0348-U1 348 Cask Wash Area None R None Detection System, 1A-107: R 0351-U1 Chiller Surge Tank Room None None None None 0400-U1 Primary Access Point None None E Plant staff Training: E 0402-U1 402 Passage to Unit 2 R R None Detection System, 1A-114: R Water Suppression, 1A-1 14: R 0403-U1 403 Hot Instrument Shop None R None Detection System, 1A-57: R 0405-U1 405 Hatch Room None R None Detection System, 1A-57: R 0406-U1 406 Decontamination Room E, R E, R E Detection System, 1A-136: E R Restricted transient controls: E Water Suppression, 1A-136: E R 0407-U1 407 Hot Machine Shop None E, R E Detection System, 1A-107: E R Restricted transient controls: E 0408-U1 408 Hallway None R None Detection System, 1A-107: R 0409-U1 409 Hallway None R E Detection System, 1A-57: R Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 20 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-Ul - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0410A-U1 410A 600-V Load Center R R None Detection System, 1A-57: R Gaseous Suppression, 1A-50: R 041OB-U1 410B 600-V Load Center R R None Detection System, 1A-57: R Gaseous Suppression, 1A-50: R 0415-Ul 415 Corridor R R None Detection System, 1A- 114: R Water Suppression, 1A-114: R 0417-Ul 417 Corridor R R None Detection System, 1A-114: R Water Suppression, 1A-114: R 0418-Ul 418 Auxiliary Building and None R None Detection System, 1A-107: R Containment Purge Vent Equipment Room 0419-U1 419 Demineralizer Hatch Area None R None Detection System, 1A-57: R 0422-U1 422 Corridor None R None Detection System, 1A-107: R 0423-U1 423 Valve Compartment None R None Detection System, 1A-107: R 0424-U 1 424 Demineralizer Compartment None None None None 0425-U1 425 Demineralizer Compartment None None None None 0426-U1 426 Demineralizer Compartment None None None None 0427-U1 427 Demineralizer Compartment None None None None 0429-U 1 429 Containment Purge Air None E, R E Detection System, 1A-108: E R Equipment Room Restricted transient controls: E 0432-U1 432 Corridor R R None Detection System, 1A-114: R Water Suppression, 1A-114: R 0438-U1 438 Hot Water Heater Room R R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0441-U1 441 Tool Room None E E Detection System, 1A-57: E Restricted transient controls: E 0445-U1 445 Spent-Fuel Pool Heat None R None Detection System, 1A-107: R Exchanger Room 0446-U1 446 Hallway None R None Detection System, 1A-107: R 0448-U1 448 SFPC Pump Room None R None Detection System, 1A-107: R 0449-U1 449 Demineralizer Room None None None None 0450-U1 450 Valve Compartment None None None None 0451-U1 451 Filter Room None None None None 0453-U1 453 Clean Janitor R R None Detection System, 1A- 108: R Water Suppression, 1A-52B: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 21 of 104 0

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-Ul - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0454-Ul 454 Lobby E, R E, R E Detection System, 1A-114: E R Restricted transient controls: E Water Suppression, 1A-1 14: E R 0455-U1 455 Clean Toilet Room (Men's) R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0456-U1 456 Drying Area R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0461-U1 461 Dosimetry Lab R None Detection System, 1A-51: R Water Suppression, 1A-52A: R Water Suppression, 1A-52B: R 0462-U1 462 Nonradioactive Vent R None Detection System, 1A-51: R Equipment Room Water Suppression, 1A-51: R 0463-U1 463 Storage Room None None Detection System, 1A-51: R 0464-U1 464 Storage Room None None Detection System, 1A-51: R 0467-U1 467 SFP Heat Exchanger Room None None Detection System, 1A-107: R 0478-U1 478 Motor Control Center Room None None Detection System, 1A-107: R 0480-U1 480 Health Physics R None Detection System, 1A-108: R Briefing/Planning Room Water Suppression, 1A-52B: R 0481-U1 481 Health Physicist Room R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0482-U1 482 Air Sample & Smear Analysis R None Detection System, 1A-108: R Rm. Water Suppression, 1A-52B: R 0483-U1 483 Passage R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0484-U1 484 Hot Toilet (Women's) R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0485-U1 485 Hot Toilet (Men's) R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0486-U1 486 Survey Preparation Room R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0487-U1 487 Instrument Calibration Room R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0488-U1 488 Instrument Issue & Storage R None Detection System, IA-108: R Rm. Water Suppression, 1A-52B: R 0489-U1 489 Waste & Decon. Foreman R None Detection System, 1A- 108: R Office Water Suppression, 1A-52B: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 22 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-Ul - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0490-Ul 490 Clean Toilet (Women's) R R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0491-Ul 491 Passage R R None Detection System, 1A-108: R Detection System, 1A-1 14: R Water Suppression, 1A-52B: R 0504-Ul 504 Stair No. 6, El. 184'-0" None R None Detection System, 1A-109: R 0505-Ul 505 Spent-Fuel Pool Vent None R None Detection System, 1A-109: R Equipment Room 0506-Ul 506 Component Cooling Surge None R None Detection System, 1A-110: R Tank Room 0604-Ul 604 Passage None E, R E Detection System, 1A-105: E R Restricted transient controls: E 0605-Ul 605 Blowdown Pumps and Surge None R None Detection System, 1A-105: R Tank Room 0606-Ul 606 Filter Room None R None Detection System, 1A-105: R 0607-Ul 607 Filter Room None R None Detection System, 1A-105: R 0608-Ul 608 Blowdown Heat Exchango None R None Detection System, 1A-105: R Room 0609-Ul 609 Storage Room None R None Detection System, 1A-105: R 0610-Ul 610 Valve Compartment Room None R None Detection System, 1A-105: R Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0140-U2 140 Waste Gas Decay Tank None None None None Drain Filter Room 0151-U2 151 Waste Gas Decay Tank None R None Detection System, 1A-102: R Rooms 0152-U2 152 Valve Compartment Room None R None Detection System, 1A-102: R 0153-U2 153 Waste Gas Compressor None R None Detection System, 1A-102: R Room 0154-U2 154 Waste Evaporator Steam None R None Detection System, 1A-102: R Generator Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 23 of 104 0 0

Attach -t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0154A-U2 154A Valve Compartment Room None R None Detection System, 1A-102: R 0155-U2 155 Passageway to Unit 2(1) None E E Detection System, 1A-25: E Restricted transient controls: E 0156-U2 156 Holdup Tank Room None None None None 0157-U2 157 Holdup Tank Room None None None None 0158-U2 158 Holdup Tank Room None None None None 0159-U2 159 Recycle Evaporator Feed None None None None Pump Room 0160-U2 160 Hatch Area R R None Detection System, 1A-118: R Water Suppression, 1A-118: R 0161-U2 161 Corridor E, R E, R E Detection System, 1A- 118: E R Restricted transient controls: E Water Suppression, 1A-118: E R 0162-U2 162 Hallway E, R E, R E Detection System, 1A-25: E R Restricted transient controls: E Water Suppression, 1A-25: E R 0163-U2 163 WDS Control Panel Room E, R E, R None Detection System, 1A-25: E R Water Suppression, 1A-25: E R 0164-U2 164 Laundry and Hot Shower R R None Detection System, 1A-25: R Tank Room/Storage Room Water Suppression, 1A-25: R 0165-U2 165 Waste Gas Decay Tank None R None Detection System, 1A-102: R Room 0166-U2 166 Waste Gas Decay Tank None R None Detection System, 1A-102: R Room 0168-U2 168 Chemical and Laundry Drain R R None Detection System, 1A-25: R Tank Room Water Suppression, 1A-25: R 0170-U2 170 Letdown Heat Exchanger None E, R None Detection System, 1A-101: E R Room 0175-U2 175 Hallway E, R E, R None Detection System, 1A-118: E R Water Suppression, 1A-1 18: E R 0176-U2 176 Secondary Spent-Resin None None None None Storage Tank Room 0177-U2 177 Pump Room None E, R None Detection System, 1A-101: E R 0178-U2 178 Filter Room None R None Detection System, 1A-101: R 0180-U2 180 Recycle Evaporator Steam None R None Detection System, 1A-101: R Generator Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 24 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0186-U2 186 Boric Acid Area R R None Detection System, 1A- 118: R Water Suppression, 1A-118: R 0187-U2 187 Hydro Test Pump Room None R None Detection System, 1A-10 1: R 0188-U2 188 Boric Acid Tank Area None R None Detection System, 1A-103: R 0203-U2 203 Waste Condenser Tanks and None R None Detection System, 1A-104: R Pump Room 0204-U2 204 Waste Evaporator Package None R None Detection System, 1A-104: R Room 0205-U2 205 Passageway to Unit 2 None E, R E Detection System, 1A-35: E R Restricted transient controls: E 0206-U2 206 Heat Exchanger Room None R None Detection System, 1A-104: R 0207-U2 207 Hatch Area E, R E, R E Detection System, 1A-35: E R Restricted transient controls: E Water Suppression, 1A-130: E R 0208-U2 208 Corridor E, R E, R E Detection System, 1A-35: E R Restricted transient controls: E Water Suppression, 1A-35: E R 0209-U2 209 Hallway R R None Detection System, 1A-35: R Water Suppression, 1A-35: R 0215-U2 215 Duct and Pipe Chase None None None None 0216-U2 216 Valve Compartments Area None R None Detection System, 1A-103: R 0217-U2 217 Volume Control Tank Room None None None None 0218-U2 218 Chiller Unit Room None None None None 0219-U2 219 Pipe Chase None None None None 0220-U2 220 Valve Compartment Room None R None Detection System, 1A-103: R 0221-U2 221 Primary Spent-Resin Storage None None None None Tank Room 0222-U2 222 Corridor R R None Detection System, 1A-35: R Water Suppression, 1A-35: R 0230-U2 230 Recycle Evaporator Package None R None Detection System, 1A-103: R Room 0231-U2 231 Sluice Pump Room None R None Detection System, 1A-103: R 0232-U2 232 Sluice Filter Room None R None Detection System, 1A-103: R 0236-U2 236 Duct Chase None None None None 0237-U2 237 Corridor None R None Detection System, 1A-103: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 25 of 104 0

0 Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0238-U2 238 Cask Storage Area None R None Detection System, 1A-103: R Detection System, 1A-107: R 0239-U2 239 Transfer Canal None None None None 0240-U2 240 Spent-Fuel Pool Room None R None Detection System, 1A-107: R 0253-U2 253 Valve Compartment None None None None 0301-U2 301 Seal Water Filter Room None R None Detection System, 1A-105: R 0302-U2 302 Recycle Evaporator Feed None R None Detection System, 1A-105: R Filter Room 0303-U2 303 Reactor Coolant Filter Room None R None Detection System, 1A-105: R 0304-U2 304 Waste Monitor None R None Detection System, 1A-105: R 0305-U2 305 Seal Injection Filter Room None R None Detection System, 1A-105: R 0306-U2 306 Recycle Evaporator Feed None None None None Demineralizer Room 0307-U2 307 Valve Compartment Room None R None Detection System, 1A-105: R 0308-U2 308 Waste Condensate and None None None None Monitor Tank Demineralizer Room 0309-U2 309 Hatch Area None' E, R E Detection System, 1A-105: E R Restricted transient controls: E 0310-U2 310 Valve Compartment Room None' R None Detection System, 1A-105: R 0311-U2 311 Recycle Evaporator None" R None Detection System, 1A-105: R Concentrates Filter Room 0312-U2 312 Corridor R R None Detection System, 1A-105: R Detection System, 1A-48: R Water Suppression, 1A-48: R 0313-U2 313 Floor Drain and Laundry None R None Detection System, 1A-105: R Tank Filter Room 0314-U2 314 Waste Evaporator Feed Filter None R None Detection System, 1A-105: R Room 0315-U2 315 Recycle Waste Condenser None R None Detection System, 1A-105: R Filter Room 0316-U2 316 Passageway to Unit 2 R E, R E Detection System, 1A-48: E R Restricted transient controls: E Water Suppression, 1A-48: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 26 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simpl ifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Descripti on System System Protection Feature Required Fire Protection Feature and System Details 0322-U2 322 Hallw way E, R E, R E Detection System, 1A-48: E R Restricted transient controls: E Water Suppression, 1A-48: E R 0323-U2 323 Sample Room None R None Detection System, 1A-49: R 0324-U2 324 Primary Chemistry Lab None R None Detection System, 1A-49: R 0325-U2 325 Counting Room/Spectro- None R None Detection System, 1A-49: R photometer Lab 0326-U2 326 Radiochemistry Lab None R None Detection System, 1A-49: R 0327-U2 327 Valve Access Area None None None None 0328-U2 328 BTR Demineralizer Room None None None None 0329-U2 329 Pipe Tunnel None None None None 0330-U2 330 Chiller Surge Tanks Pump None R None Detection System, 1A-48: R Room 0331 -U2 331 Valve Access Area None R None Detection System, 1A-48: R 0332-U2 332 MCC 1A/2A Area None R None Detection System, 1A-48: R 0340-U2 340 Demineralizer Compartment None None None None 0341-U2 341 Pipe Chase None None None None 0342-U2 342 Spent-Fuel Pool Pump Room None R None Detection System, 1A-48: R 0348-U2 348 Cask Wash Area None None None None 0351-U2 Chiller Surge Tank Room None R None Detection System, 1A-48: R 0400-U2 Primary Access Point None None E Plant staff Training: E 0402-U2 402 Passage to Unit 2 R R None Detection System, 1A-1 14: R Water Suppression, 1A-1 14: R 0403-U2 403 Hot Instrument Shop None R None Detection System, 1A-57: R 0405-U2 405 Hatch Room None R None Detection System, 1A-57: R 0406-U2 406 Decontamination Room E, R E, R E Detection System, 1A-136: E R Restricted transient controls: E Water Suppression, 1A-136: E R 0407-U2 407 Hot Machine Shop None E, R E Detection System, 1A-107: E R Restricted transient controls: E 0408-U2 408 Hallway None R None Detection System, 1A-107: R 0409-U2 409 Hallway None E, R E Detection System, 1A-57: E R Restricted transient controls: E 041 OA-U2 410A 600-V Load Center R R None Detection System, 1A-57: R Gaseous Suppression, 1A-50: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 27 of 104

Attachtt C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0410B-U2 410B 600-V Load Center R R None Detection System. 1A-57: R Gaseous Suppression, 1A-50: R 0415-U2 415 Corridor R R None Detection System, 1A-1 14: R Water Suppression, 1A-114: R 0417-U2 417 Corridor R R None Detection System, 1A-1 14: R Water Suppression, 1A-1 14: R 0418-U2 418 Auxiliary Building and None R None Detection System, 1A-107: R Containment Purge Vent Equipment Room 0419-U2 419 Demineralizer Hatch Area None R None Detection System, 1A-57: R 0422-U2 422 Corridor None None None None 0423-U2 423 Valve Compartment None R None Detection System, 1A-107: R 0424-U2 424 Demineralizer Compartment None None None None 0425-U2 425 Demineralizer Compartment None None None None 0426-U2 426 Demineralizer Compartment None None None None 0427-U2 427 Demineralizer Compartment None None None None 0429-U2 429 Containment Purge Air None E, R E Detection System, 1A-108: E R Equipment Room Restricted transient controls: E 0432-U2 432 Corridor R R None Detection System, 1A- 114: R Water Suppression, 1A-1 14: R 0438-U2 438 Hot Water Heater Room R R None Detection System, 1A-1 08: R Water Suppression, 1A-52B: R 0441-U2 441 Tool Room None E, R E Detection System, 1A-57: E R Restricted transient controls: E 0445-U2 445 Spent-Fuel Pool Heat None R None Detection System, 1A-107: R Exchanger Room 0446-U2 446 Hallway None None None None 0448-U2 448 SFPC Pump Room None None None None 0449-U2 449 Demineralizer Room None None None None 0450-U2 450 Valve Compartment None None None None 0451-U2 451 Filter Room None None None None 0453-U2 453 Clean Janitor R R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0454-U2 454 Lobby E, R E, R E Detection System, 1A-114: E R Restricted transient controls: E

                                                                           .1.                                            Water Suppression, 1A-1 14: E R Fire Safety Analysis Data Manager (4.2)                                                    Farley                                                       Run: 09/14/2012 08:11 Page: 28 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0455-U2 455 Clean Toilet Room (Men's) R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0456-U2 456 Drying Area R None Detection System, IA-108: R Water Suppression, 1A-52B: R 0461-U2 461 Dosimetry Lab R None Detection System, 1A-51: R Water Suppression, 1A-52B: R 0462-U2 462 Nonradioactive Vent R None Detection System, 1A-51: R Equipment Room Water Suppression, 1A-51: R 0463-U2 463 Storage Room None None Detection System, 1A-51: R 0464-U2 464 Storage Room None None Detection System, 1A-51: R 0467-U2 467 SFP Heat Exchanger Room None None Detection System, 1A-107: R 0478-U2 478 Motor Control Center Room None None Detection System, 1A-1 07: R 0480-U2 480 Health Physics R None Detection System, 1A-1 08: R Briefing/Planning Room Water Suppression, 1A-52B: R 0481-U2 481 Health Physicist Room R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0482-U2 482 Air Sample & Smear Analysis R None Detection System, 1A-108: R Rm. Water Suppression, 1A-52B: R 0483-U2 483 Passage R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0484-U2 484 Hot Toilet (Women's) R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0485-U2 485 Hot Toilet (Men's) R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0486-U2 486 Survey Preparation Room R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0487-U2 487 Instrument Calibration Room R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0488-U2 488 Instrument Issue & Storage R None Detection System, 1A-108: R Rm. Water Suppression, 1A-52B: R 0489-U2 489 Waste & Decon. Foreman R None Detection System, 1A-1 08: R Office Water Suppression, 1A-52B: R 0490-U2 490 Clean Toilet (Women's) R None Detection System, 1A-108: R Water Suppression, 1A-52B: R 0491-U2 491 Passage R None Detection System, 1A-108: R Detection System, 1A-114: R Water Suppression, 1A-52B: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 29 of 104 0

Attach" t Ci Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systemsand Features Fire Area ID: 1-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0504-U2 504 Stair No. 6, El. 184'-0" None R None Detection System, 1A-109: R 0505-U2 505 Spent-Fuel Pool Vent None R None Detection System, 1A-109: R Equipment Room 0506-U2 506 Component Cooling Surge None R None Detection System, 1A-110: R Tank Room 0604-U2 604 Passage None E, R E Detection System, 1A-105: E R Restricted transient controls: E 0605-U2 605 Blowdown Pumps and Surge None R None Detection System, IA-105: R Tank Room 0606-U2 606 Filter Room None R None Detection System, 1A-105: R 0607-U2 607 Filter Room None R None Detection System, 1A-105: R 0608-U2 608 Blowdown Heat Exchanger None R None Detection System, 1A-105: R Room 0609-U2 609 Storage Room None R None Detection System, 1A-105: R 0610-U2 610 Valve Compartment Room None R None Detection System, 1A-105: R Fire Area ID: 1-005 - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0172 172 Hallway E, R, D E, R, D E, D Detection System, 1A- 118: E R D Restricted transient controls: E D Water Suppression, 1A-118: E R D 0173 173 Charging/Safety Injection None E, R, D None Detection System, 1A-101: E R D Pump Room 0174 174 Charging/Safety Injection None E, R, D None Detection System, 1A-101: E R D Pump Room 0181 181 Charging/Safety Injection None E, R, D None Detection System, 1A-101: E R D Pump Room 0182 182 Contaminated Storage Area None R, D None Detection System, 1A-10 1: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 30 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-006 - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation withhsimplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Descripti on System System Protection Feature Required Fire Protection Feature and System Details (All) Area Widee None None R, D Modifications: R D 0185 185 Comp)onent Coolinq Water E, R, D E, R, D E Detection System, 1A-119: E R D Heat Exchhanger Room Detection System, 1A-27: E R D Detection System, Heat Detectors: R D Restricted transient controls: E Water Suppression, 1A-119: E R D Water Suppression, 1A-27: E R D 0189 189 Plant Heating Equipment R, D R, D None Detection System, 1A-62: R D Room Water Suppression, 1A-62: R D 0190 190 Motor Control Center 1E E, R, D E, R, D E Detection System, 1A-62: E R D Room Restricted transient controls: E Water Suppression, 1A-62: E R D 0191 191 Auxiliary Feedwater Pump None R, D None Detection System, 1A-102: R D Room 0192 192 Auxiliary Feedwater Pump None R, D None Detection System, 1A-102: R D Room 0193 193 Auxiliary Feedwater Pump None R, D None Detection System, 1A-102: R D Room 0194 194 Equipment Room R R, D None Detection System, 1A-62: R D Water Suppression, 1A-62: R 0195 195 Access Hatch Room None None None None 0199 199 Phosphate Tank and Pump None None E Curbs: E Area 0241 241 Main Steam and Feedwater None E, R, D None Detection System, 1A-106: E R D Valve Room 0242 242 Pipe Chase None None None None 0243 243 Pipe Chase None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 31 of 104 0 I* 0

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems. and Features 0 Fire Area ID: 1-008-Ul -Aux Building Cable Chase, Room 116 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0116-Ul 116 Cable Chase E, R E, R, D E Detection System, 1A-53: E R D Restricted transient controls: E Water Suppression, 1A-53: E R Fire Area ID: 1-008-U2 -Aux Building Cable Chase, Room 116 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 0116-U2 116 Cable Chase E, R E, R, D E Detection System, 1A-53: E R D Restricted transient controls: E Water Suppression, 1A-53: E R Fire Area ID: 1-009-Ul - Aux Building Cable Chase, Rooms 117 & 246 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0117-U1 117 Cable Chase E, R, D E, R, D E, D Detection System, 1A-55: E R D Restricted transient controls: E D Water Suppression, 1A-55: E R D 0246-U1 246 Cable Chase R, D R, D D Detection System, 1A-55: R D Restricted transient controls: D Water Suppression, 1A-55: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 32 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-009-U2 - Aux Building Cable Chase, Rooms 117 & 246 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0117-U2 117 Cable Chase E, R E, R, D E Detection System, 1A-55: E R D Restricted transient controls: E Water Suppression, 1A-55: E R 0246-U2 246 Cable Chase R R, D None Detection System, 1A-55: R D Water Suppression, 1A-55: R Fire Area ID: 1-012 - Hallway & Local Hot Shutdown Panel Room Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0254 254 Hallway/Local Hot Shutdown None E, R, D E, D Detection System, 1A-104: E R D Panel Room Plant staff Training: E Restricted transient controls: E D Fire Area ID: 1-013-U1 - Aux Building Cable Chase, Rooms 227, 300, 465, 466, & 500 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0227-U1 227 Vertical Cable Chase, El. R, S R, D, S R, S Detection System, 1A-23: R D S 128'-0" One Hour Rated Cable: R S Water Suppression, 1A-23: R S 0300-U1 300 Vertical Cable Chase, El 141 R, S R, D, S R, S Detection System, 1A-23: R D S ft 0 in. One Hour Rated Cable: R S Water Suppression, 1A-23: R S 0465-U1 465 Vertical Cable Chase, El. None R, D None Detection System, 1A-23: R D 155'-0" 0466-U1 466 Vertical Cable Chase, El. R, D R, D None Detection System, 1A-23: R D 155'-0" Water Suppression, 1A-23: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 33 of 104

Attach*t CI Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 1-013-Ul - Aux Building Cable Chase, Rooms 227, 300, 465, 466, & 500 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0500-Ul 500 Vertical Cable Chase, El. R, D R, D None Detection System, 1A-23: R D 168'-6" Water Suppression, 1A-23: R D Fire Area ID: 1-013-U2 - Aux Building Cable Chase, Rooms 227, 300, 465, 466, & 500 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0227-U2 227 Vertical Cable Chase, El. R, S R, S R, S Detection System, 1A-23: R S 128'-0" One Hour Rated Cable: R S Water Suppression, 1A-23: R S 0300-U2 300 Vertical Cable Chase, El 141 R, S R, S R, S Detection System, 1A-23: R S ft 0 in. One Hour Rated Cable: R S Water Suppression, 1A-23: R S 0465-U2 465 Vertical Cable Chase, El. R R None Detection System, 1A-23: R 155'-0" Water Suppression, 1A-23: R 0466-U2 466 Vertical Cable Chase, El. R R None Detection System, 1A-23: R 155'-0" Water Suppression, 1A-23: R 0500-U2 500 Vertical Cable Chase, El. R R None Detection System, 1A-23: R 168'-6" Water Suppression, 1A-23: R Fire Area ID: 1-014 - Computer Room & Duct Chase Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0201 201 Computer Room E D None Detection System, 1A-33: D Gaseous Suppression, 1A-33: E 0255 255 Duct Chase None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 34 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-015 - Communication Room Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0202 202 Communication Room E, R, D E, R, D E Detection System, 1A-34: E R D Gaseous Suppression, 1A-34: E R D Restricted transient controls: E Fire Area ID: 1-016 - Aux Building Battery Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0212 212 Battery Room None E E Detection System, 1A-32: E Restricted transient controls: E Fire Area ID: 1-017 - Aux Building Battery Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Su'ppression Detection Required Fire Fire Zone ID Description Systt.n System Protection Feature Required Fire Protection Feature and System Details 0214 214 Battery Room None E E Detection System, 1A-32: E Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 35 of 104

0 Attachftt C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-018 - Aux Building DC Switchgear Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Modifications: R D 0224 224 dc Switchgear Room None R, D None Detection System, 1A-32: R D Fire Area ID: 1-019 - Aux Building DC Switchgear Room Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0226 226 dc Switchgear Room None E, R, D E Detection System, 1A-32: E R D Restricted transient controls: E Fire Area ID: 1-020 - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Modifications: R D 0210 210 Corridor E, R E, R, D E Detection System, 1A-36: E R D Restricted transient controls: E Water Suppression, 1A-36: E R 0211 211 Corridor R R, D None Detection System, 1A-36: R D Water Suppression, 1A-36: R 0213 213 Battery Service Room E, R E, R, D E Detection System, 1A-32: E R D Restricted transient controls: E Water Suppression, 1A-36: E R 0225 225 Battery Charger Room None E, R, D E Detection System, 1A-32: E R D Restricted transient controls: E 0228 228 Corridor E, R E, R, D E Detection System, 1A-36: E R D Restricted transient controls: E Water Suppression, 1A-36: E R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 36 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-020 - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0234 234 Hallway E, R E, R, D E Detection System, 1A-36: E R D Restricted transient controls: E Water Suppression, 1A-36: E R 0244 244 Roof of Battery 1B Room, El. R R, D None Detection System, 1A-36: R D 131'-0" Water Suppression, 1A-36: R 0245 245 Roof of Battery 1A Room, El. R R, D None Detection System, 1A-36: R D 131'-0" , Water Suppression, 1A-36: R Fire Area ID: 1-021-U 1 - Aux Building Switchgear Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0229-U1 229 Switchgear Room E, R, D E, R, D E Detection System, 1A-104: E R D Gaseous Suppression, 1A-28: E R D Gaseous Suppression, 1A-29: E R D Restricted transient controls: E 0233-U1 233 Switchgear Room E, R, D E, R, D E Detection System, 1A-104: E R D Gaseous Suppression, 1A-28: E R D Gaseous Suppression, 1A-30: E R D Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 37 of 104

Attachat C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-021-U2 - Aux Building Switchgear Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 0229-U2 .229 Switchgear Room E, R, D E, R, D E Detection System, 1A-104: E R D Gaseous Suppression, 1A-28: E R D Gaseous Suppression, 1A-29: E R D Restricted transient controls: E 0233-U2 233 Switchgear Room E, R, D E, R, D E Detection System, 1A-104: E R D Gaseous Suppression, 1A-28: E R D Gaseous Suppression, 1A-30: E R D Restricted transient controls: E Fire Area ID: 1-023-Ul - Aux Building Switchgear Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0235-Ul 235 Switchgear Room E, R E, R, D E Detection System, 1A-31: E R D Gaseous Suppression, 1A-31: E R Restricted transient controls: E Fire Area ID: 1-023-U2 - Aux Building Switchgear Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0235-U2 235 Switchgear Room E, R E, R, D E Detection System, 1A-31: E R D Gaseous Suppression, 1A-31: E R Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 38 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-030-Ul - Aux Building Cable Chase, Rooms 249 & 252 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0249-Ul 249 Cable Chase D D None Detection System, 1A-61: D Water Suppression, 1A-61i: D 0252-Ul 252 Cable Chase E, D E, D None Detection System, 1A-61: E D Water Suppression, 1A-61: E D Fire Area ID: 1-030-U2 - Aux Building Cable Chase, Rooms 249 & 252 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0249-U2 249 Cable Chase None D None Detection System, 1A-61: D 0252-U2 252 Cable Chase E E, D None Detection System, 1A-61: E D Water Suppression, 1A-61: E Fire Area ID: 1-031-Ul - Aux Building Cable Chase, Rooms 250 & 251 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0250-U1 250 Cable Chase E, D E, R, D E Detection System, 1A-60: E R D Restricted transient controls: E Water Suppression, 1A-60: E D 0251-U1 251 Cable Chase E, D E, R, D None Detection System, lA-60: E R D Water Suppression, 1A-60: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 39 of 104 0

Attachit C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 1-031-U2 - Aux Building Cable Chase, Rooms 250 & 251 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 0250-U2 250 Cable Chase E, D E, R, D E Detection System, 1A-60: E R D Restricted transient controls: E Water Suppression, 1A-60: E D 0251-U2 251 Cable Chase E, D E, R, D None Detection System, 1A-60: E R D Water Suppression, 1A-60: E D Fire Area ID: 1-034 - Train B Electrical Pen Room & Filtration System Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0317 317 Penetration Room Filtration None E, R, D E Detection System, 1A-48: E R D System Equipment Room Restricted transient controls: E 0334 334 Electrical Penetration Room, R E, R, D E Detection System, 1A-45: E R D Train B Detection System, 1A-46: E R D Restricted transient controls: E Water Suppression, 1A-45: R Fire Area ID: 1-035 - Train A Electrical Pen Rooms Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0333 333 Electrical Penetration Room, None E, R, D E Detection System, 1A-47: E R D Train A Restricted transient controls: E 0347 347 Electrical Penetration Room None R, D None Detection System, 1A-47: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 40 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-039 - Fuel Storage & Storage Rack Pits Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0349 349 Pits for New Fuel Storage None None None None Racks 0350 350 Pits for New Fuel Storage None None None None Racks 0459 459 New Fuel Storage Room None None None None Fire Area ID: 1-040-U1 - Cable Spreading Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D (All) Area Wide None None R, D Modifications: R D 0318-Ul 318 Cable Spreading Room E, D E, R, D E Detection System, 1A-43: E R D Restricted transient controls: E Water Suppression, 1A-43: E D Fire Area ID: 1-040-U2 - Cable Spreading Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 0318-U2 318 Cable Spreading Room E, D E, R, D E Detection System, 1A-43: E R D Restricted transient controls: E Water Suppression, 1A-43: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 41 of 104

0 Attachlt C C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-041-U1 - Train A Switchgear & Load Center Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 0335-Ul 335 Load Center Room, Train A E, R, D E, R, D E, R, D Detection System, 1A-39: E R D Detection System, 1A-40: E R D Detection System, 1A-41: E R D Gaseous Suppression, 1A-40: E R D Gaseous Suppression, 1A-41: E R D One Hour Rated Cable: R Restricted transient controls: E D 0343-Ul 343 Load Center Room, Train A E, R, D E, R, D E, R Detection System, 1A-39: E R D Detection System, 1A-40: E R D Detection System, 1A-42: E R D Gaseous Suppression, 1A-40: E R D Gaseous Suppression, 1A-42: E R D One Hour Rated Cable: R Restricted transient controls: E 0346-Ul 346 Switchgear and M-G Set E, R, D E, R, D E Detection System, 1A-37: E R D Room Detection System, 1A-38: E R D Detection System, 1A-39: E R D Gaseous Suppression, 1A-37: E R D Gaseous Suppression, 1A-38: E R D Restricted transient controls: E Fire Area ID: 1-041-U2 - Train A Switchgear & Load Center Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 0335-U2 335 Load Center Room, Train A E, R, D E, R, D E, R Detection System, 1A-39: E R D Detection System, 1A-40: E R D Detection System, 1A-41: E R D Gaseous Suppression, 1A-40: E R D Gaseous Suppression, 1A-41: E R D One Hour Rated Cable: R Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 42 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-041-U2 - Train A Switchgear & Load Center Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0343-U2 343 Load Center Room, Train A E, R, D E, R, D E, R Detection System, 1A-39: E R D Detection System, 1A-40: E R D Detection System, 1A-42: E R D Gaseous Suppression, 1A-40: E R D Gaseous Suppression, 1A-42: E R D One Hour Rated Cable: R Restricted transient controls: E 0346-U2 346 Switchgear and M-G Set E, R, D E, R, D E Detection System, 1A-37: E R D Room Detection System, 1A-38: E R D Detection System, 1A-39: E R D Gaseous Suppression, 1A-37: E R D Gaseous Suppression, 1A-38: E R D Restricted transient controls: E Fire Area ID: 1-042-Ul - Aux Building Hallways & Corridor Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Modifications: R D 0319-U1 319 Corridor - Train B E, S E, D, S E, R, S Detection System, 1A-59: E D S One Hour Rated Cable: R S Restricted transient controls: E Water Suppression, 1A-59: E S 0339-U1 339 Corridor - Train A E, S E, D, S E, R, S Detection System, 1A-59: E D S One Hour Rated Cable: R S Restricted transient controls: E Water Suppression, 1A-59: E S 0345-U1 345 Hallway - Train A E, D E, D D Detection System, 1A-59: E D Restricted transient controls: D Water Suppression, 1A-59: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 43 of 104 0.

Attach ,tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-042-U2 - Aux Building Hallways & Corridor Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 0319-U2 319 Corridor - Train B E, S E, D, S E, R, S Detection System, 1A-59: E D S One Hour Rated Cable: R S Restricted transient controls: E Water Suppression, 1A-59: E S 0339-U2 339 Corridor - Train A E, S E, D, S E, R, S Detection System, 1A-59: E D S One Hour Rated Cable: R S Restricted transient controls: E Water Suppression, 1A-59: E S 0345-U2 345 Hallway - Train A E, D E, D None Detection System, 1A-59: E D Water Suppression, 1A-59: E D Fire Area ID: 1-053 - Aux Building Elevator Machine Room No. 2 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0502 502 Elevator Machine Room No. None None None None 2 Fire Area ID: 1-054 - Aux Building Elevator Machine Room No. 1 and Elevator No. 1 Shaft Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0503 503 Elevator Machine Room No. None None None None 1 and Elevator No. 1 Shaft Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 44 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-055 - Containment Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-CTMT Containment, Unit 1 None D None Detection System, 1A-22: D Fire Area ID: 1-075-Ul - Unit 1 Cable Tunnel - Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R, D Modifications: R D 1-075-U1 Unit 1 Cable Tunnel - Train A E, D None None Water Suppression, 1 D-77: E D Fire Area ID: 1-075-U2 - Unit 1 Cable Tunnel - Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 1-075-U2 Unit 1 Cable Tunnel - Train A E, D None None Water Suppression, 1D-77: E D Fire Area ID: 1-076-Ul - Unit 1 Cable Tunnel - Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 1-076-U1 Unit 1 Cable Tunnel - Train B E, D None E Restricted transient controls: E Water Suppression, 1D-98: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 45 of 104 0 0

S Attach* tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features A* Fire Area ID: 1-076-U2 - Unit 1 Cable Tunnel - Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-076-U2 Unit 1 Cable Tunnel - Train B E, D None E Restricted transient controls: E Water Suppression, 1D-98: E D Fire Area ID: 1-077 - Condensate Storage Tank Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-CST Condensate Storage Tank None None None None Fire Area ID: 1-078 - Reactor Makeup Storage Tank Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-RWMT Reactor Makeup Storage Tank None None None None Fire Area ID: 1-079 - Refueling Water Storage Tank Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-RWST Refueling Water Storage Tank None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 46 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-080 - Low Voltage Switchyard - Unit 1 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-080A Main Transformer No.3 E None E Curbs: E Water Suppression, 1TR-64: E 1-080B Main Transformer No.2 E None E Curbs: E Water Suppression, 1TR-64: E 1-080C Main Transformer No.1 E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 1TR-66: E 1-080D Main Transformer (Spare) E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 1TR-66: E 1-080E Unit Aux Transformer No. 1A None None E Combustibles and flammable liquid control: E Curbs: E 1-080F Unit Aux Transformer (Spare E None E Combustibles and flammable liquid control: E Cubicle) Curbs: E Water Suppression, 1TR-68: E 1-080G Startup Aux Transformer No. 1A E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 1TR-67: E 1-080H Startup Aux Transformer No. 1B E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 1TR-69: E 1-080J Startup Aux Transformer (Spare) None None E Combustibles and flammable liquid control: E 1-080K Low Voltage Switchyard - None None E Combustibles and flammable liquid control: E General Area, Unit 1 Curbs: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 47 of 104 0 0

0 Attach tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-081-Ul - Turbine Building Battery Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 1-081-Ul Turbine Building Battery Room None None None None Fire Area ID: 1-081-U2 - Turbine Building Battery Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-081-U2 Turbine Building Battery Room None D None Detection System, 1T-4: D Fire Area ID: 1-082 - Turbine Building Lube Oil Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-082 Lube Oil Storage Room None None None None Fire Area ID: 1-083 - Turbine Building Oil Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-083 Oil Storage Room None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 48 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-086 - Turbine Building Auxiliary Steam Generator Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-086 Auxiliary Steam Generator None None None None Fire Area ID: 1-090 - Aux Building Combustible Storage &.Filter Unit Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0107 107 Combustible Storage/Filter E E E Detection System, 1A-132: E Unit Room Restricted transient controls: E Water Suppression, 1A-132: E Fire Area ID: 1-092 - Drumming Station & Storage & Combustible Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0420 420 Drum Storage/Combustible None None None None Storage Room 0421 421 Drumming None None None None Station/Combustible Storage Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 49 of 104 S

0 Attach&t C 1 Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-094 - Aux Building Combustible Storage Room Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying!deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0167 167 Combustible Storage Room None D None Detection System, 1A-27: D Fire Area ID: 1-095 - Aux Building Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0171 171 Storage Room/Combustible E E None Detection System, 1A-118: E Storage Room Water Suppression, 1A-118: E Fire Area ID: 1-096 - Aux Building Combustible Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0179 179 Combustible Storage Room E E None Detection System, 1A-118: E Water Suppression, 1A-118: E Fire Area ID: 1-097 - Filter Hatch Room & Combustible Storage Area Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0404 404 Filter Hatch None None None None Room/Combustible Storage Area Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 50 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-098 - Caskwash Storage & Combustible Storage Area Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 0447 447 Caskwash Storage None None None None Area/Combustible Storage Area Fire Area ID: 1-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 1, Train A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-DU-DGRWIS-A Diesel Building to RWIS None None None None Ductbank, Unit 1, Train A Fire Area ID: 1-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 1, Train B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-DU-DGRWIS-B Diesel Building to RWIS None None None None Ductbank, Unit 1, Train B Fire Area ID: 1-DU-DGSWIS-A-U1 - Diesel Building to SWIS Ductbank, Unit 1, Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Modifications: D 1-DU-DGSWIS-A-U1 Diesel Building to SWIS None None None None Ductbank, Unit 1, Train A Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 51 of 104

Attach*-t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-DU-DGSWIS-A-U2 - Diesel Building to SWIS Ductbank, Unit 1, Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 1-DU-DGSWIS-A-U2 Diesel Building to SWIS None None None None Ductbank, Unit 1, Train A Fire Area ID: 1-DU-DGSWIS-B-U1 - Diesel Building to SWIS Ductbank, Unit 1, Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 1-DU-DGSWIS-B-U1 Diesel Building to SWIS None None None None Ductbank, Unit 1, Train B Fire Area ID: 1-DU-DGSWIS-B-U2 - Diesel Building to SWIS Ductbank, Unit 1, Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-DU-DGSWIS-B-U2 Diesel Building to SWIS None None None None Ductbank, Unit 1, Train B Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 52 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-DU-DGVB-A - Diesel Building to Valve Box Ductbanks, Train A Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-DU-DGVB-A Diesel Building to Valve Box None None None None Ductbanks, Train A Fire Area ID: 1-DU-DGVB-B - Diesel Building to Valve Box Ductbanks, Train B Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-DU-DGVB-B Diesel Building to Valve Box None None None None Ductbanks, Train B Fire Area ID: 1-EMBED-AB - Aux Building Embedded Conduit Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-EMBED-AB Embedded Conduit, Auxiliary None None None None Building, Unit 1 Fire Area ID: 1-SO1 - Stairwell No. 1 Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-S01 Stairwell No. 1 None E E Detection System, IA-51: E Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 53 of 104 0"

Attach*it C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 1-S02 - Stairwell No. 2 Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-S02 Stairwell No. 2 None E E, R, S Detection System, 1A-108: E Restricted transient controls: E Three Hour Rated

Enclosure:

R S Fire Area ID: I-S08 - Stairwell No. 8 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-S08 Stairwell No. 8 None None E Restricted transient controls: E Fire Area ID: 1-S10 - Stairwell No. 10 Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-S1O Stairwell No. 10 None None E Restricted transient controls: E Fire Area ID: 1-SVB1-A - Service Water Valve Box, 1-SVB1, Train A Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 1-SVB1-A Service Water Valve Box, 1- None None None None SVB1, Train A Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 54 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-SVB1-B - Service Water Valve Box, 1-SVB1, Train B Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 1-SVB1-B Service Water Valve Box, 1- None None None None SVB1, Train B Fire Area ID: 1-SVB2-A - Service Water Valve Box, 1-SVB2, Train A Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 1-SVB2-A Service Water Valve Box, 1- None None None None SVB2, Train A Fire Area ID: 1-SVB2-B - Service Water Valve Box, 1-SVB2, Train B Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R I-SVB2-B Service Water Valve Box, 1- None None None None SVB2, Train B Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 55 of 104 0

0 ,Attach C Ct Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-SVB3-A - Service Water Valve Box, 1-SVB3, Train A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-SVB3-A Service Water Valve Box, 1- None None None None SVB3, Train A Fire Area ID: 1 -SVB3-B - Service Water Valve Box, 1-SVB3, Train B Compliance Basis: NFPA 805. Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-SVB3-B Service Water Valve Box, 1- None None None None SVB3, Train B Fire Area ID: 1-SVB4-A - Service Water Valve Box, 1-SVB4, Train A Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R I-SVB4-A Service Water Valve Box, 1- None None None None SVB4, Train A Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 56 of 104

Attachment C Table C-2, Tqble 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 1-SVB4-B - Service Water Valve Box, 1-SVB4, Train B Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 1-SVB4-B Service Water Valve Box, 1- None None None None SVB4, Train B Fire Area ID: 1-TB-U 1 - Turbine Building General Area Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach -Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 1-084-U1 Turbine, SGFP, and Hw Seal Oil D None None Water Suppression, 1T-12B: D Conditioners & Reservoirs Water Suppression, 1T-2: D Water Suppression, 1T-3: D Water Suppression, 1T-9: D 1-085-U1 Turbine Building, General Area D None None Water Suppression, 1T-10: D Water Suppression, 1T-12B: D Water Suppression, 1T-16C: D Water Suppression, 1T-16D: D Water Suppression, 1T-16E: D Water Suppression, 1T-I8: D Water Suppression, 1T-2: D 1-087-U1 Steam Generator Feed Pumps A D None None Water Suppression, 1T-17: D

                        &B                                                                                                Water Suppression, 1T-20: D 1-088-U1                 Turbine Building Switchgear Area     R,D                None              None                    Gaseous Suppression, 1T-13: R D Gaseous Suppression, 1T-14: R D Fire Safety Analysis Data Manager (4.2)                                                    Farley                                                      Run: 09/14/2012 08:11 Page: 57 of 104 0

Attachlt C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 9 Fire Area ID: 1-TB-U2 - Turbine Building General Area Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-084-U2 Turbine, SGFP, and Hw Seal Oil None None None None Conditioners & Reservoirs 1-085-U2 Turbine Building, General Area None D None Detection System, 1T-16A: D Detection System, 1T-16B: D Detection System, 1T-16C: D Detection System, 1T-16D: D Detection System, 1T-16E: D 1-087-U2 Steam Generator Feed Pumps A None D None Detection System, 1T-17: D

                        &B                                                                                                Detection System, 1T-20: D 1-088-U2                 Turbine Building Switchgear Area    R                D                   None                     Detection System, 1T-13: D Gaseous Suppression, 1T-13: R Gaseous Suppression, 1T-14: R Fire Area ID:                      2-001 - Aux Building Compliance Basis:                  NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required         Required Suppression      Detection           Required Fire Fire Zone ID             Description                         System           System              Protection Feature       Required Fire Protection Feature and System Details (All)                    Area Wide                           None             None                R                        Procedures/Recovery Actions: R (All)                    Area Wide                           None             None                R                        Modifications: R 2101                     2101 Waste Gas Decay Tank           None             R, D                None                     Detection System, 2A-100: R D Room 2102                     2102 Valve Compartment Room         None             R, D                None                     Detection System, 2A-100: R D 2103                     2103 Corridor                       None             E, R, D             None                     Detection System, 2A-100: E R D 2104                     2104 Passageway to Unit 1           None             E, R, D             E                        Detection System, 2A-100: E R D Plant staff Training: E Restricted transient controls: E 2105                     2105 Catalytic H2 Recombiner        None             R, D                None                     Detection System, 2A-100: R D 1A Room 2106                     2106 Catalytic H2 Recombiner        None             R, D                None                     Detection System, 2A-100: R D 1B Room 2108                     2108 Waste Monitor Tank Room        None             R, D                None                     Detection System, 2A-100: R D 2109                     2109 Waste Monitor Tank Pump        None             R, D                None                     Detection System, 2A-100: R D Room 2110                     2110 Monitor Control Panel          None             R, D                None                     Detection System, 2A-100: R D Room Fire Safety Analysis Data Manager (4.2)                                                   Farley                                                       Run: 09/14/2012 08:11 Page: 58 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-001 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2111 2111 Containment Spray Pump None R, D None Detection System, 2A-100: R D Room 1A 2112 2112 Access to Tendon Access None None None None Gallery 2113 2113 Valve Encapsulation None R, D None Detection System, 2A-100: R D 2114 2114 Pipe Chase None None None None 2115 2115 Hallway None None E Restricted transient controls: E 2118 2118 Floor Drain Tank Room None R, D None Detection System, 2A-100: R D 2119 2119 Waste Holdup Tank Room None R, D None Detection System, 2A-1 00: R D 2120 2120 Corridor None R, D None Detection System, 2A-100: R D 2121 2121 Floor Drain Tank Pump None R, D None Detection System, 2A-100: R D Room 2122 2122 Waste Evaporator Feed None R, D None Detection System, 2A-100: R D Pump Room 2123 2123 Pipe Chase None None None None 2124 2124 Valve Encapsulation None R, D None Detection System, 2A-100: R D 2125 2125 Containment Spray Pump None E, R, D None Detection System, 2A-1 00: E R D Room 1B 2126 2126 Pipe Chase None None None None 2127 2127 Pipe Chase None None None None 2128 2128 RHR Heat Exchanger None R, D None Detection System, 2A-1 00: R D Room 2129 2129 RHR Low Head Pump None R, D None Detection System, 2A-1 00: R D Room 2130 2130 Pipe Chase None None None None 2131 2131 RHR Low Head Pump None R, D None Detection System, 2A-100: R D Room 2169 2169 Duct and Pipe Chase None None None None 2183 2183 Tendon Access Gallery None E, R, D E Detection System, 2A-100: E R D Entrance Detection System, 2A-101: R D Restricted transient controls: E 2184 2184 Piping Penetration Room, D R, D None Detection System, 2A-102: R D El. 100'-0" Water Suppression, 2A-45: D 2196 2196 Access to Tendon Access None None None None Gallery Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 59 of 104

0 Attach. tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems'and Features Fire Area ID: 2-001 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2223 2223 Piping Penetration Room, D R, D None Detection System, 2A-45: R D El. 121'-0" Water Suppression, 2A-45: D Fire Area ID: 2-004-Ul - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2151-Ul 2151 Waste Gas Decay Tank None R None Detection System, 2A-102: R Rooms 2152-U1 2152 Valve Compartment Room None R None Detection System, 2A-102: R 2153-U1 2153 Waste Gas Compressor None R None Detection System, 2A-102: R Room 2154-U1 2154 Waste Evaporator Steam None R None Detection System, 2A-102: R Generator Room 2154A-U1 2154A Valve Compartment Room None R None Detection System, 2A-25: R 2155-U1 2155 Passageway to Unit 1 E E, R E Detection System, 2A-25: E R Restricted transient controls: E Water Suppression, 2A-25: E 2156-U1 2156 Holdup Tank Room None R None Detection System, 2A-104: R 2157-Ul 2157 Holdup Tank Room None R None Detection System, 2A-104: R 2158-U1 2158 Holdup Tank Room None R None Detection System, 2A-104: R 2159-U1 2159 Recycle Evaporator Feed None R None Detection System, 2A-101 : R Pump Room 2160-U1 2160 Hatch Area E, R E, R E Detection System, 2A-25: E R Restricted transient controls: E Water Suppression, 2A-25: E R 2161-Ul 2161 Corridor E, R E, R E Detection System, 2A-25: E R Restricted transient controls: E Water Suppression, 2A-25: E R 2162-Ul 2162 Hallway E, R E, R E Detection System, 2A-25: E R Restricted transient controls: E Water Suppression, 2A-25: E R 2163-U1 2163 WDS Control Panel Room E, R E, R None Detection System, 2A-25: E R Water Suppression, 2A-25: E R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 60 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-Ul - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2164-Ul 2164 Storage Room None R None Detection System, 2A-25: R 2165-U1 2165 Waste Gas Decay Tank None R None Detection System, 2A-102: R Room 2166-U1 2166 Waste Gas Decay Tank None R None Detection System, 2A-102: R Room 2168-U1 2168 Chemical Drain Tank Room None R None Detection System, 2A-25: R 2170-Ul 2170 Letdown Heat Exchanger None E, R None Detection System, 2A-101: E R Room 2175-U1 2175 Hallway E, R E, R None Detection System, 2A-118: E R Water Suppression, 2A-118: E R 2176-U1 2176 Secondary Spent-Resin None None None None Storage Tank Room 2177-U1 2177 Pump Room None E, R None Detection System, 2A-101: E R 2178-U1 2178 Filter Room None R None Detection System, 2A-101: R 2180-U1 2180 Recycle Evaporator Steam None R None Detection System, 2A-101: R Generator Room 2186-U1 2186 Boric Acid Area None R None Detection System, 2A-101: R 2187-U1 2187 Hydro Test Pump Room None R None Detection System, 2A-101: R 2188-U1 2188 Boric Acid Tank Area None R None Detection System, 2A-103: R 2203-U1 2203 Waste Condenser Tanks None R None Detection System, 2A-1 04: R and Pump Room 2204-U1 2204 Waste Evaporator Package None R None Detection System, 2A-104: R Room 2205-U1 2205 Passageway to Unit 1 None E E Detection System, 2A-35: E Restricted transient controls: E 2206-U1 2206 Heat Exchanger Room None R None Detection System, 2A-104: R 2207-U1 2207 Hatch Area E, R E, R E Detection System, 2A-35: E R Restricted transient controls: E Water Suppression, 2A-35: E R 2208-U1 2208 Corridor R R None Detection System, 2A-35: R Water Suppression, 2A-35: R 2209-U1 2209 Hallway E, R E, R E Detection System, 2A-35: E R Restricted transient controls: E Water Suppression, 2A-35: E R 2215-Ul 2215 Duct and Pipe Chase None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 61 of 104

O Attach~t C O Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-U1 - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2216-U1 2216 Valve Compartments Area None R None Detection System, 2A-103: R 2217-Ul 2217 Volume Control Tank Room None R None Detection System, 2A-103: R 2218-U1 2218 Chiller Unit Room None R None Detection System, 2A-1 03: R 2219-U1 2219 Pipe Chase None None None None 2220-U1 2220 Valve Compartment Room None R None Detection System, 2A-103: R 2221-Ul 2221 Primary Spent-Resin None None None None Storage Tank Room 2222-U1 2222 Corridor R R None Detection System, 2A-35: R Water Suppression, 2A-35: R 2230-U1 2230 Recycle Evaporator None R None Detection System, 2A-103: R Package Room 2231-U1 2231 Sluice Pump Room None R None Detection System, 2A-103: R 2232-Ul 2232 Sluice Filter Room None R None Detection System, 2A-103: R 2237-U1 2237 Corridor None R None Detection System, 2A-103: R 2238-U1 2238 Cask Storage Area None R None Detection System, 2A-1 07: R 2239-U1 2239 Transfer Canal None None None None 2240-U1 2240 Spent-Fuel Pool Room None R None Detection System, 2A-107: R 2253-U1 2253 Valve Compartment None R None Detection System, 2A-104: R 2301-U1 2301 Seal Water Filter Room None R None Detection System, 2A-105: R 2302-U1 2302 Recycle Evaporator Feed None R None Detection System, 2A-105: R Filter Room 2303-U1 2303 Reactor Coolant Filter None R None Detection System, 2A-105: R Room 2304-U1 2304 Waste Monitor None R None Detection System, 2A-1 05: R 2305-U1 2305 Seal Injection Filter Room None R None Detection System, 2A-1 05: R 2306-U1 2306 Recycle Evaporator Feed None None None None Demineralizer Room 2307-U1 2307 Valve Compartment Room None R None Detection System, 2A-105: R 2308-U1 2308 Waste Condensate and None None None None Monitor Tank Demineralizer Room 2309-U1 2309 Hatch Area None E, R E Detection System, 2A-48: E R Restricted transient controls: E 2310-Ul 2310 Valve Compartment Room None R None Detection System, 2A-105: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 62 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-Ul - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2311-U1 2311 Recycle Evaporator None R None Detection System, 2A-105: R Concentrates Filter Room 23.12-Ul 2312 Corridor R E, R E Detection System, 2A-48: E R Restricted transient controls: E Water Suppression, 2A-48: R 2313-Ul 2313 Floor Drain and Laundry None R None Detection System, 2A-105: R Tank Filter Room 2314-U1 2314 Waste Evaporator Feed None R None Detection System, 2A-105: R Filter Room 2315-U1 2315 Recycle Waste Condenser None R None Detection System, 2A-105: R Filter Room 2316-U1 2316 Passageway to Unit 1 E, R E, R E Detection System, 2A-48: E R Restricted transient controls: E Water Suppression, 2A-48: E R 2321-U1 2321 Sample Panel Room None R None Detection System, 2A-49: R 2322-U1 2322 Hallway E, R E, R E Detection System, 2A-48: E R Restricted transient controls: E Water Suppression, 2A-48: E R 2323-U1 2323 Sample Room None R None Detection System, 2A-49: R 2324-U1 2324 Primary Chemistry Lab None R None Detection System, 2A-49: R 2325-U1 2325 Counting Room/Spectro- None R None Detection System, 2A-49: R photometer Lab 2326-U1 2326 Clean Storage Room None R None Detection System, 2A-49: R 2327-U1 2327 Valve Access Area None None None None 2328-U1 2328 BTR Demineralizer Room None None None None 2329-U1 2329 Pipe Tunnel None None None None 2330-U1 2330 Chiller Surge Tanks Pump None R None Detection System, 2A-48: R Room 2331-U1 2331 Valve Access Area None R None Detection System, 2A-48: R 2332-U1 2332 MCC 1A/2A Area None R None Detection System, 2A-48: R 2340-U1 2340 Demineralizer Compartment None None None None 2341-Ul 2341 Pipe Chase None None None None 2342-U1 2342 Spent-Fuel Pool Pump None R None Detection System, 2A-48: R Room 2348-U1 2348 Cask Wash Area None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 63 of 104 S

0 Attachit C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-Ul - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2351-Ul 2351 Chiller Pump and Surge None None None None Tank Room 2402-U1 2402 Passage to Unit 1 R R None Detection System, 2A-57: R Water Suppression, 2A-57: R 2403-U1 2403 Respirator Issue R R None Detection System, 2A-1 12: R Room/Combustible Storage Water Suppression, 2A-112: R Room 2405-U1 2405 Hatch Room E, R E, R E Detection System, 2A-75: E R Restricted transient controls: E Water Suppression, 2A-75: E R 2406-U1 2406 Tool Room E, R E, R E Detection System, 2A-75: E R Restricted transient controls: E Water Suppression, 2A-75: E R 2408-U1 2408 Hallway None E, R E Detection System, 2A-57: E R Restricted transient controls: E 2409-Ul 2409 Hallway None R None Detection System, 2A-107: R Detection System, 2A-57: R 241OA-U1 2410A 600-V Load Center R R None Detection System, 2A-57: R Gaseous Suppression, 2A-50: R 2418-U1 2418 Auxiliary Building and None R None Detection System, 2A-107: R Containment Purge Vent Equipment Room 2419-U1 2419 Demineralizer Hatch Area R R None Detection System, 2A-75: R Water Suppression, 2A-75: R 2422-U1 2422 Corridor None E, R E Detection System, 2A-107: E R Restricted transient controls: E 2423-U 1 2423 Valve Compartment None R None Detection System, 2A-107: R 2424-U1 2424 Demineralizer None None None None Compartments 2425-U1 2425 Demineralizer None None None None Compartments 2426-U1 2426 Demineralizer None None None None Compartments 2427-U1 2427 Demineralizer None None None None Compartments Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 64 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-Ul - Aux Building Compliance Basis: Unit 1: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 2: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2429-Ul 2429 Containment Purqe Air None E, R E Detection System, 2A-108: E R Equipment Room Restricted transient controls: E 2431-U1 2431 Duct/Pipe Chase None None None None 2445-U1 2445 Spent-Fuel Pool Heat None R None Detection System, 2A-107: R Exchanger Room 2446-U1 2446 Hallway None R None Detection System, 2A-107: R 2448-U1 2448 SFPC Pump Room None None None None 2449-U1 2449 Demineralizer Room None None None None 2450-U1 2450 Valve Compartment None None None None 2451-U1 2451 Filter Room None None None None 2467-U1 2467 SFP Heat Exchanger Room None R None Detection System, 2A-107: R 2478-U1 2478 Motor Control Center Room None R None Detection System, 2A-107: R 2504-U1 2504 Stair No. 6, Floor El. 184'-0" None R None Detection System, 2A-109: R 2505-U1 2505 Spent-Fuel Pool Vent None R None Detection System, 2A-109: R Equipment Room 2604-U1 2604 Passage None E, R E Detection System, 2A-105: E R Restricted transient controls: E 2605-U1 2605 Blowdown Pumps and None R None Detection System, 2A-105: R Surge Tank Room 2606-U1 2606 Filter Room None R None Detection System, 2A-105: R 2607-U1 2607 Filter Room None R None Detection System, 2A-105: R 2608-U1 2608 Blowdown Heat Exchanger None R None Detection System, 2A-105: R Room 2609-U1 2609 Storage Room None R None Detection System, 2A-105: R 2610-U1 2610 Valve Compartment Room None R None Detection System, 2A-105: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 65 of 104

SAttach ,tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems'and Features Fire Area ID: 2-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2151-U2 2151 Waste Gas Decay Tank None R None Detection System, 2A-102: R Rooms 2152-U2 2152 Valve Compartment Room None R None Detection System, 2A-102: R 2153-U2 2153 Waste Gas Compressor None R None Detection System, 2A-102: R Room 2154-U2 2154 Waste Evaporator Steam None R None Detection System, 2A-102: R Generator Room 2154A-U2 2154A Valve Compartment Room None R None Detection System, 2A-25: R 2155-U2 2155 Passageway to Unit 1 E E E Detection System, 2A-25: E Restricted transient controls: E Water Suppression, 2A-25: E 2156-U2 2156 Holdup Tank Room None R None Detection System, 2A-104: R 2157-U2 2157 Holdup Tank Room None R None Detection System, 2A-104: R 2158-U2 2158 Holdup Tank Room None R None Detection System, 2A-104: R 2159-U2 2159 Recycle Evaporator Feed None R None Detection System, 2A-101: R Pump Room 2160-U2 2160 Hatch Area E, R E, R E Detection System, 2A-25: E R Restricted transient controls: E Water Suppression, 2A-25: E R 2161-U2 2161 Corridor E, R E, R E Detection System, 2A-25: E R Restricted transient controls: E Water Suppression, 2A-25: E R 2162-U2 2162 Hallway E, R, D E, R, D E, D Detection System, 2A-25: E R D Restricted transient controls: E D Water Suppression, 2A-25: E R D 2163-U2 2163 WDS Control Panel Room E, R, D E, R, D D Detection System, 2A-25: E R D Restricted transient controls: D Water Suppression, 2A-25: E R D 2164-U2 2164 Storage Room None R None Detection System, 2A-25: R 2165-U2 2165 Waste Gas Decay Tank None R None Detection System, 2A-102: R Room 2166-U2 2166 Waste Gas Decay Tank None R None Detection System, 2A-102: R Room 2168-U2 2168 Chemical Drain Tank Room None R None Detection System, 2A-25: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 66 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2170-U2 2170 Letdown Heat Exchanger None E, R None Detection System, 2A-101: E R Room 2175-U2 2175 Hallway E, R E, R None Detection System, 2A-118: E R Water Suppression, 2A-118: E R 2176-U2 2176 Secondary Spent-Resin None None None None Storage Tank Room 2177-U2 2177 Pump Room None E, R None Detection System, 2A-101: E R 2178-U2 2178 Filter Room None R None Detection System, 2A-101 : R 2180-U2 2180 Recycle Evaporator Steam None R None Detection System, 2A-101: R Generator Room 2186-U2 2186 Boric Acid Area None R, D D Detection System, 2A-101: R D Restricted transient controls: D 2187-U2 2187 Hydro Test Pump Room None R None Detection System, 2A-101: R 2188-U2 2188 Boric Acid Tank Area None R None Detection System, 2A-1 03: R 2203-U2 2203 Waste Condenser Tanks None R None Detection System, 2A-1 04: R and Pump Room 2204-U2 2204 Waste Evaporator Package None R None Detection System, 2A-1 04: R Room 2205-U2 2205 Passageway to Unit 1 None E E Detection System, 2A-35: E Restricted transient controls: E 2206-U2 2206 Heat Exchanger Room None R None Detection System, 2A-104: R 2207-U2 2207 Hatch Area E, R E, R E Detection System, 2A-35: E R Restricted transient controls: E Water Suppression, 2A-35: E R 2208-U2 2208 Corridor R R None Detection System, 2A-35: R Water Suppression, 2A-35: R 2209-U2 2209 Hallway E, R E, R E Detection System, 2A-35: E R Restricted transient controls: E Water Suppression, 2A-35: E R 2215-U2 2215 Duct and Pipe Chase None None None None 2216-U2 2216 Valve Compartments Area None R None Detection System, 2A-103: R 2217-U2 2217 Volume Control Tank Room None R None Detection System, 2A-103: R 2218-U2 2218 Chiller Unit Room None R None Detection System, 2A-103: R 2219-U2 2219 Pipe Chase None None None None 2220-U2 2220 Valve Compartment Room None R None Detection System, 2A-103: R Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 67 of 104

Attach*t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2221-U2 2221 Primary Spent-Resin None None None None Storage Tank Room 2222-U2 2222 Corridor R, D R, D None Detection System, 2A-35: R D Water Suppression, 2A-35: R D 2230-U2 2230 Recycle Evaporator None R None Detection System, 2A-103: R Package Room 2231 -U2 2231 Sluice Pump Room None R None Detection System, 2A-103: R 2232-U2 2232 Sluice Filter Room None R None Detection System, 2A-103: R 2237-U2 2237 Corridor None R None Detection System, 2A-103: R 2238-U2 2238 Cask Storage Area None R None Detection System, 2A-107: R 2239-U2 2239 Transfer Canal None. None None None 2240-U2 2240 Spent-Fuel Pool Room None R None Detection System, 2A-1 07: R 2253-U2 2253 Valve Compartment None R None Detection System, 2A-104: R 23011-U2 2301 Seal Water Filter Room None R None Detection System, 2A-1 05: R 2302-U2 2302 Recycle Evaporator Feed None R None Detection System, 2A-105: R Filter Room 2303-U2 2303 Reactor Coolant Filter None R None Detection System, 2A-105: R Room 2304-U2 2304 Waste Monitor None R None Detection System, 2A-105: R 2305-U2 2305 Seal Injection Filter Room None R None Detection System, 2A-105: R 2306-U2 2306 Recycle Evaporator Feed None None None None Demineralizer Room 2307-U2 2307 Valve Compartment Room None R None Detection System, 2A-105: R 2308-U2 2308 Waste Condensate and None None None None Monitor Tank Demineralizer Room 2309-U2 2309 Hatch Area None E, R E Detection System, 2A-48: E R Restricted transient controls: E 231 0-U2 2310 Valve Compartment Room None R None Detection System, 2A-105: R 2311-U2 2311 Recycle Evaporator None R None Detection System, 2A-105: R Concentrates Filter Room 2312-U2 2312 Corridor R E, R E Detection System, 2A-48: E R Restricted transient controls: E Water Suppression, 2A-48: R 2313-U2 2313 Floor Drain and Laundry None R None Detection System, 2A-105: R Tank Filter Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 68 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fiire Protection Feature and System Details 2314-U2 2314 Waste Evaporator Feed None R None Detection System, 2A-105: R Filter Room 2315-U2 2315 Recycle Waste Condenser None R None Detection System, 2A-105: R Filter Room 2316-U2 2316 Passageway to Unit 1 E, R E, R E Detection System, 2A-48: E R Restricted transient controls: E Water Suppression, 2A-48: E R 2321 -U2 2321 Sample Panel Room None R None Detection System, 2A-49: R 2322-U2 2322 Hallway E, R E, R E Detection System, 2A-48: E R Restricted transient controls: E Water Suppression, 2A-48: E R 2323-U2 2323 Sample Room None R None Detection System, 2A-49: R 2324-U2 2324 Primary Chemistry Lab None R None Detection System, 2A-49: R 2325-U2 2325 Counting Room/Spectro- None R None Detection System, 2A-49: R photometer Lab 2326-U2 2326 Clean Storage Room None R None Detection System, 2A-49: R 2327-U2 2327 Valve Access Area None None None None 2328-U2 2328 BTR Demineralizer Room None None None None 2329-U2 2329 Pipe Tunnel None None None None 2330-U2 2330 Chiller Surge Tanks Pump None R None Detection System, 2A-48: R Room 2331-U2 2331 Valve Access Area None R None Detection System, 2A-48: R 2332-U2 2332 MCC 1A/2A Area None R, D D Detection System, 2A-48: R D Restricted transient controls: D 2340-U2 2340 Demineralizer Compartment None None None None 2341-U2 2341 Pipe Chase None None None None 2342-U2 2342 Spent-Fuel Pool Pump None R None Detection System, 2A-48: R Room 2348-U2 2348 Cask Wash Area None None None None 2351-U2 2351 Chiller Pump and Surge None None None None Tank Room 2402-U2 2402 Passage to Unit 1 R R None Detection System, 2A-57: R Water Suppression, 2A-57: R 2403-U2 2403 Respirator Issue R R None Detection System, 2A-1 12: R Room/Combustible Storage Water Suppression, 2A-1 12: R Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 69 of 104

0 Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systemsland Features Fire Area ID: 2-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2405-U2 2405 Hatch Room E, R E, R E Detection System, 2A-75: E R Restricted transient controls: E Water Suppression, 2A-75: E R 2406-U2 2406 Tool Room E, R E, R E Detection System, 2A-75: E R Restricted transient controls: E Water Suppression, 2A-75: E R 2408-U2 2408 Hallway None E, R E Detection System, 2A-57: E R Restricted transient controls: E 2409-U2 2409 Hallway None R None Detection System, 2A-107: R Detection System, 2A-57: R 241 OA-U2 2410A 600-V Load Center R R None Detection System, 2A-57: R Gaseous Suppression, 2A-50: R 2418-U2 2418 Auxiliary Building and None R None Detection System, 2A-107: R Containment Purge Vent Equipment Room 2419-U2 2419 Demineralizer Hatch Area R, D R, D D Detection System, 2A-75: R D Restricted transient controls: D Water Suppression, 2A-75: R D 2422-U2 2422 Corridor None E, R E Detection System, 2A-107: E R Restricted transient controls: E 2423-U2 2423 Valve Compartment None R None Detection System, 2A-107: R 2424-U2 2424 Demineralizer None None None None Compartments 2425-U2 2425 Demineralizer None None None None Compartments 2426-U2 2426 Demineralizer None None None None Compartments 2427-U2 2427 Demineralizer None None None None Compartments 2429-U2 2429 Containment Purge Air None E, R E Detection System, 2A-108: E R Equipment Room Restricted transient controls: E 2431-U2 2431 Duct/Pipe Chase None None None None 2445-U2 2445 Spent-Fuel Pool Heat None R None Detection System, 2A-107: R Exchanger Room 2446-U2 2446 Hallway None R None Detection System, 2A-107: R 2448-U2 2448 SFPC Pump Room None None None None 2449-U2 2449 Demineralizer Room None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 70 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-004-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2450-U2 2450 Valve Compartment None None None None 2451-U2 2451 Filter Room None None None None 2467-U2 2467 SFP Heat Exchanger Room None R None Detection System, 2A-107: R 2478-U2 2478 Motor Control Center Room None R None Detection System, 2A-107: R 2504-U2 2504 Stair No. 6, Floor El. 184'-0" None R None Detection System, 2A-109: R 2505-U2 2505 Spent-Fuel Pool Vent None R None Detection System, 2A-109: R Equipment Room 2604-U2 2604 Passage None E, R E Detection System, 2A-1 05: E R Restricted transient controls: E 2605-U2 2605 Blowdown Pumps and None R None Detection System, 2A-105: R Surge Tank Room 2606-U2 2606 Filter Room None R None Detection System, 2A-105: R 2607-U2 2607 Filter Room None R None Detection System, 2A-1 05: R 2608-U2 2608 Blowdown Heat Exchanger None R None Detection System, 2A-1 05: R Room 2609-U2 2609 Storage Room None R None Detection System, 2A-105: R 2610-U2 2610 Valve Compartment Room None R None Detection System, 2A-105: R Fire Area ID: 2-005 - Aux Building Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2171 2171 Storage Room None E, R None Detection System, 2A-101: E R 2172 2172 Hallway E, D E, R, D E Detection System, 2A-101: E R D Restricted transient controls: E Water Suppression, 2A-101: E D 2173 2173 Charging/Safety Injection None E, R None Detection System, 2A- 101: E R Pump Room 2174 2174 Charging/Safety Injection None E, R None Detection System, 2A-101: E R Pump Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 71 of 104

0 Attachtt C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-005 - Aux Building Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2181 2181 Charging/Safety Injection None E, R, D None Detection System, 2A-101: E R D Pump Room 2182 2182 Contaminated Storage Area None R, D None Detection System, 2A-101: R D Fire Area ID: 2-006 - Aux Building Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Modifications: R D 2185 2185 Component Cooling Water E, R E, R E Detection System, 2A-1 19: E R Heat Exchanger Room Detection System, 2A-27: E R Restricted transient controls: E Water Suppression, 2A-27: E R 2189 2189 Plant Heating Equipment R R None Detection System, 2A-62: R Room Water Suppression, 2A-62: R 2190 2190 Motor Control Center 2E E, R E, R E Detection System, 2A-62: E R Room Restricted transient controls: E Water Suppression, 2A-62: E R 2191 2191 Auxiliary Feedwater Pump None R None Detection System, 2A-1 02: R Room 2192 2192 Auxiliary Feedwater Pump None R, D None Detection System, 2A-102: R D Room 2193 2193 Auxiliary Feedwater Pump None R None Detection System, 2A-102: R Room 2194 2194 Equipment Room None R None Detection System, 2A-62: R 2195 2195 Access Hatch Room None None None None 2199 2199 Phosphate Tank and Pump R R E Curbs: E Area Detection System, 2A-62: R Water Suppression, 2A-62: R 2236 2236 Duct Chase None None None None 2241 2241 Main Steam and Feed- None E, R None Detection System, 2A-106: E R water Valve Room 2242 2242 Pipe Chase None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 72 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-006 - Aux Building Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2243 2243 Pipe Chase None None None None Fire Area ID: 2-008-Ul - Aux Building Cable Chase, Room 2116 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2116-Ul 2116 Cable Chase E, R E, R, D E Detection System, 2A-53: E R D Restricted transient controls: E Water Suppression, 2A-53: E R Fire Area ID: 2-008-U2 - Aux Building Cable Chase, Room 2116 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R, D Modifications: R D 2116-U2 2116 Cable Chase E, R, D E, R, D E Detection System, 2A-53: E R D Restricted transient controls: E Water Suppression, 2A-53: E R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 73 of 104 0

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 2-009-Ul - Aux Building Cable Chase, Rooms 2117 & 2246 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2117-Ul 2117 Cable Chase E, R E, R, D E Detection System, 2A-55: E R D Restricted transient controls: E Water Suppression, 2A-55: E R 2246-Ul 2246 Cable Chase R R, D None Detection System, 2A-55: R D Water Suppression, 2A-55: R Fire Area ID: 2-009-U2 - Aux Building Cable Chase, Rooms 2117 & 2246 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2117-U2 2117 Cable Chase E, R, D E, R, D E, D Detection System, 2A-55: E R D Restricted transient controls: E D Water Suppression, 2A-55: E R D 2246-U2 2246 Cable Chase R, D R, D D Detection System, 2A-55: R D Restricted transient controls: D Water Suppression, 2A-55: R D Fire Area ID: 2-012 - Hallway & Local Hot Shutdown Panel Room Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2254 2254 Hallway/Local Hot None E, R, D E Detection System, 2A-104: E R D Shutdown Panel Room Plant staff Training: E Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 74 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-013-Ul - Aux Building Cable Chase, Rooms 2227, 2300, 2466, & 2500 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2227-Ul 2227 Vertical Cable Chase, El. None None None None 128'-0" 2300-Ul 2300 Vertical Cable Chase, El. S S S Detection System, 2A-23: S 141'-0" One Hour Rated Cable: S Water Suppression, 2A-23: S 2466-Ul 2466 Vertical Cable Chase, El. None None None None 1556-0" 2500-Ul 2500 Vertical Cable Chase, El. None None None None 168'-6" Fire Area ID: 2-013-U2 - Aux Building Cable Chase, Rooms 2227, 2300, 2466, & 2500 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2227-U2 2227 Vertical Cable Chase, El. R, D R, D D Detection System, 2A-23: R D 128'-0" Restricted transient controls: D Water Suppression, 2A-23: R D 2300-U2 2300 Vertical Cable Chase, El. R, S R,SS R, S Detection System, 2A-43: R S 141'-0" One Hour Rated Cable: R S Water Suppression, 2A-23: R S j 2466-U2 2466 Vertical Cable Chase, El. R, D R, D D Detection System, 2A-23: R D 155'-0" Restricted transient controls: D Water Suppression, 2A-23: R D 2500-U2 2500 Vertical Cable Chase, El. R, D R, D D Detection System, 2A-23: R D 168'-6" Restricted transient controls: D Water Suppression, 2A-23: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 75 of 104 0

Attachat C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 2-014 - Computer Room Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying'deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2201 2201 Computer Room None D None Detection System, 2A-33: D Fire Area ID: 2-015 - Communication Room Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2202 2202 Communication Room E, R, D E, R, D E Detection System, 2A-34: E R D Gaseous Suppression, 2A-34: E R D Restricted transient controls: E Fire Area ID: 2-016 - Aux Building Battery Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2212 2212 Battery Room None None None None Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 76 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-017 - Aux Building Battery Room Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2214 2214 Battery Room None D None Detection System, 2A-32: D Fire Area ID: 2-018 - Aux Building DC Switchgear Room Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R, D Modifications: R D 2224 2224 dc Switchgear Room None E, R, D E Detection System, 2A-32: E R D Restricted transient controls: E Fire Area ID: 2-019 - Aux Building DC Switchgear Room Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2226 2226 dc Switchgear Room None E, R, D E Detection System, 2A-32: E R D Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 77 of 104 S

0 Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-020 - Aux Building Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Modifications: R D 2210 2210 Corridor E, R, D E, R, D E Detection System, 2A-36: E R D Restricted transient controls: E Water Suppression, 2A-36: E R D 2211 2211 Corridor R R, D None Detection System, 2A-36: R D Water Suppression, 2A-36: R 2213 2213 Battery Service Room R R, D None Detection System, 2A-32: R D Water Suppression, 2A-36: R 2225 2225 Battery Charger Room None E, R, D E Detection System, 2A-32: E R D Restricted transient controls: E 2228 2228 Corridor None E, R, D E Detection System, 2A-36: E R D Restricted transient controls: E 2234 2234 Hallway E, R E, R, D E Detection System, 2A-36: E R D Restricted transient controls: E Water Suppression, 2A-36: E R 2244 2244 Roof of Battery 2B Room, R, D R, D None Detection System, 2A-36: R D El. 131'-0" Water Suppression, 2A-36: R D 2245 2245 Roof of Battery 2A Room, R R, D None Detection System, 2A-36: R D El. 131'-0" Water Suppression, 2A-36: R Fire Area ID: 2-021-Ul - Aux Building Switchgear Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2229-U1 2229 Switchgear Room R R, D None Detection System, 2A-104: R D Gaseous Suppression, 2A-28: R 2233-U1 2233 Switchgear Room E, R E, R, D E Detection System, 2A-104: E R D Gaseous Suppression, 2A-28: E R Gaseous Suppression, 2A-30: E R Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 78 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-021-U2 - Aux Building Switchgear Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2229-U2 2229 Switchgear Room R, D R, D None Detection System, 2A-104: R D Gaseous Suppression, 2A-28: R D Gaseous Suppression, 2A-29: R D 2233-U2 2233 Switchgear Room E, R, D E, R, D E Detection System, 2A-104: E R D Gaseous Suppression, 2A-28: E R D Gaseous Suppression, 2A-30: E R D Restricted transient controls: E Fire Area ID: 2-023-Ul - Aux Building Switchgear Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2235-Ul 2235 Switchgear Room E, R E, R, D E Detection System, 2A-31: E R D Gaseous Suppression, 2A-31: E R Restricted transient controls: E Fire Area ID: 2-023-U2 - Aux Building Switchgear Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2235-U2 2235 Switchgear Room E, R E, R, D E Detection System, 2A-31: E R D Gaseous Suppression, 2A-31: E R Restricted transient controls: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 79 of 104 0

O Attachl tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-030-U1 - Aux Building Cable Chase, Rooms 2249 & 2252 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2249-Ul 2249 Cable Chase E E, R, D E Detection System, 2A-60: E R D Restricted transient controls: E Water Suppression, 2A-60: E 2252-Ul 2252 Cable Chase E E, R, D None Detection System, 2A-60: E R D Water Suppression, 2A-60: E Fire Area ID: 2-030-U2 - Aux Building Cable Chase, Rooms 2249 & 2252 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2249-U2 2249 Cable Chase E, D E, R, D E Detection System, 2A-60: E R D Restricted transient controls: E Water Suppression, 2A-60: E D 2252-U2 2252 Cable Chase E, D E, R, D None Detection System, 2A-60: E R D Water Suppression, 2A-60: E D Fire Area ID: 2-031-U1 - Aux Building Cable Chase, Rooms 2250 & 2251 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2250-U1 2250 Cable Chase D D None Detection System, 2A-61: D Water Suppression, 2A-61: D 2251-U1 2251 Cable Chase E, D E, D None Detection System, 2A-61: E D Water Suppression, 2A-61: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 80 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-031-U2 - Aux Building Cable Chase, Rooms 2250 & 2251 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2250-U2 2250 Cable Chase D D None Detection System, 2A-61: D Water Suppression, 2A-61: D 2251-U2 2251 Cable Chase E, D E, D None Detection System, 2A-61: E D Water Suppression, 2A-61: E D Fire Area ID: 2-034 - Train B Electrical Pen Room & Filtration System Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2317 2317 Penetration Room Filtration None R, D None Detection System, 2A-48: R D System Equipment Room 2334 2334 Electrical Penetration R, D E, R, D E Detection System, 2A-46: E R D Room, Train B Restricted transient controls: E Water Suppression, 2A-45: R D Fire Area ID: 2-035 - Train A Electrical Pen Rooms Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2333 2333 Electrical Penetration None E, R, D E Detection System, 2A-47: E R D Room, Train A Restricted transient controls: E 2347 2347 Electrical Penetration Room None R, D None Detection System, 2A-47: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 81 of 104

O Attacht C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-039 - Fuel Storage & Storage Rack Pits Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2349 2349 Pits for New Fuel Storage None None None None Racks 2350 2350 Pits for New Fuel Storage None None None None Racks 2459 2459 New Fuel Storage Room None None None None Fire Area ID: 2-040-Ul - Cable Spreading Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2318-Ul 2318 Cable Spreading Room E E, R, D E Detection System, 2A-43: E R D Restricted transient controls: E Water Suppression, 2A-43: E Fire Area ID: 2-040-U2 - Cable Spreading Room Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D (All) Area Wide None None R, D Modifications: R D 2318-U2 2318 Cable Spreading Room E, D E, R, D E Detection System, 2A-43: E R D Restricted transient controls: E Water Suppression, 2A-43: E D Fire Safety Analysis Date Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 82 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-041-Ul - Train A Switchgear & Load Center Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2335-Ul 2335 Load Center Room, Train A E, R, D E, R, D E, R Detection System, 2A-39: E R D Gaseous Suppression, 2A-40: E R D Gaseous Suppression, 2A-41: E R D One Hour Rated Cable: R Restricted transient controls: E 2343-Ul 2343 Load Center Room, Train A E, R, D E, R, D E Detection System, 2A-39: E R D Gaseous Suppression, 2A-40: E R D Gaseous Suppression, 2A-42: E R D Restricted transient controls: E 2346-Ul 2346 Switchgear and M-G Set E, R, D E, R, D E Detection System, 2A-39: E R D Room Gaseous Suppression, 2A-37: E R D Gaseous Suppression, 2A-38: E R D Restricted transient controls: E Fire Area ID: 2-041-U2 - Train A Switchgear & Load Center Rooms Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R, D Modifications: R D 2335-U2 2335 Load Center Room, Train A E, R, D E, R, D E, R Detection System, 2A-39: E R D Gaseous Suppression, 2A-40: E R D Gaseous Suppression, 2A-41: E R D One Hour Rated Cable: R Restricted transient controls: E 2343-U2 2343 Load Center Room, Train A E, R, D E, R, D E Detection System, 2A-39: E R D Gaseous Suppression, 2A-40: E R D Gaseous Suppression, 2A-42: R D Restricted transient controls: E 2346-U2 2346 Switchgear and M-G Set E, R, D E, R, D E, D Detection System, 2A-39: E R D Room Gaseous Suppression, 2A-37: E R D Gaseous Suppression, 2A-38: E R D Restricted transient controls: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 83 of 104

0 Attachft C i Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-042-Ul - Aux Building Hallways & Corridor Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2319-Ul 2319 Corridor - Train B E, R, S E, R, D, S E, R, S Detection System, 2A-59: E R D S One Hour Rated Cable: R S Restricted transient controls: E Water Suppression, 2A-59: E R S 2339-Ul 2339 Corridor - Train A E, R, S E, R, D, S E, R, S Detection System, 2A-59: E R D S One Hour Rated Cable: R S Restricted transient controls: E Water Suppression, 2A-59: E R S 2345-Ul 2345 Hallway - Train A E, R E, R, D None Detection System, 2A-59: E R D Water Suppression, 2A-59: E R Fire Area ID: 2-042-U2 - Aux Building Hallways & Corridor Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2319-U2 2319 Corridor - Train B E, R None E, R One Hour Rated Cable: R Restricted transient controls: E Water Suppression, 2A-59: E R 2339-U2 2339 Corridor - Train A E, R None E, R One Hour Rated Cable: R Restricted transient controls: E Water Suppression, 2A-59: E R 2345-U2 2345 Hallway - Train A E, R, D E, R, D D Detection System, 2A-59: E R D Restricted transient controls: D Water Suppression, 2A-59: E R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 84 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-043-Ul - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-S12-U1 Stairwell No. 12 None None None None 2452-U1 2452 Storage Area E E, R E Detection System, 2A-51: E R Restricted transient controls: E Water Suppression, 2A-52: E 2462-Ul 2462 Nonradioactive Ventilation None R None Detection System, 2A-51: R Equipment Room 2463-Ul 2463 Storage Room None R None Detection System, 2A-51: R 2464-U1 2464 Storage Room None R None Detection System, 2A-51: R 2502-Ul 2502 Unassigned Area None R None Detection System, 2A-110: R 2506-Ul 2506 Component Cooling Surge None R None Detection System, 2A-110: R Tank Room Fire Area ID: 2-043-U2 - Aux Building Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Modifications: D 2-S12-U2 Stairwell No. 12 None None None None 2452-U2 2452 Storage Area E, D E, R, D E Detection System, 2A-51: E R D Restricted transient controls: E Water Suppression, 2A-52: E D 2462-U2 2462 Nonradioactive Ventilation D R, D None Detection System, 2A-51: R D Equipment Room Water Suppression, 2A-51: D 2463-U2 2463 Storage Room None R, D None Detection System, 2A-51: R D 2464-U2 2464 Storage Room None R, D None Detection System, 2A-51: R D 2502-U2 2502 Unassigned Area None R, D None Detection System, 2A-110: R D 2506-U2 2506 Component Cooling Surge None R, D None Detection System, 2A-1 10: R D Tank Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 85 of 104 0

Attach*t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-054 - Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2503 2503 Elevator Machine Room No. None D None Detection System, 2A-1 10: D 4 and Elevator No. 1 Shaft Fire Area ID: 2-055 - Containment Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-CTMT Containment, Unit 2 R R, D D Detection System, 2A-22: R D Hose Stations: R RCP Oil Collection System: D Fire Area ID: 2-075-Ul - Unit 2 Cable Tunnel - Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-075-U1 Unit 2 Cable Tunnel - Train A E, D None E Restricted transient controls: E Water Suppression, 2D-77: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 86 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-075-U2 - Unit 2 Cable Tunnel - Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R, D Modifications: R D 2-075-U2 Unit 2 Cable Tunnel - Train A E, D None E Restricted transient controls: E Water Suppression, 2D-77: E D Fire Area ID: 2-076-U1 - Unit 2 Cable Tunnel - Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-076-Ul Unit 2 Cable Tunnel - Train B E, D None E Restricted transient controls: E Water Suppression, 2D-98: E D Fire Area ID: 2-076-U2 - Unit 2 Cable Tunnel - Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R (All) Area Wide None None R Modifications: R 2-076-U2 Unit 2 Cable Tunnel - Train B E, D None E Restricted transient controls: E Water Suppression, 2D-98: E D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 87 of 104

Attachft C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 2-077 - Condensate Storage Tank: Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-CST Condensate Storage Tank None None None None Fire Area ID: 2-078 - Reactor Makeup Storage Tank Compliance Basis: NFPA 805, Section 4,2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-RWMT Reactor Makeup Storage Tank None None None None Fire Area ID: 2-079 - Refueling Water Storage Tank Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-RWST Refueling Water Storage Tank None None None None Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-080A Main Transformer No. 3 E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 2TR-64: E 2-080B Main Transformer No. 2 E None E Curbs: E Water Suppression, 2TR-66: E 2-080C Main Transformer No. 1 E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 2TR-66: E 2-080D Main Transformer (Spare) E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 2TR-64: E Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 88 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-080 - Low Voltage Switchyard - Unit 2 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-080E Unit Aux Transformer (Spare None None E Combustibles and flammable liquid control: E Cubicle) Curbs: E 2-080F Unit Aux Transformer 2B E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 2TR-67: E 2-080G Startup Aux Transformer No. 2B E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 2TR-69: E 2-080H Startup Aux Transformer No. 2A E None E Combustibles and flammable liquid control: E Curbs: E Water Suppression, 2TR-65: E 2-080K Low Voltage Switchyard - None None E Combustibles and flammable liquid control: E General Area, Unit 2 Curbs: E Fire Area ID: 2-081 - Turbine Building Battery Room Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2-081 Turbine Building Battery Room None R, D None Detection System, 2T-4: R D Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 89 of 104

Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 2-089 - Lube Oil & Combustible Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2150 2150 Lube Oil None None None None Storage/Combustible Storage Room Fire Area ID: 2-090 - Aux Building Combustible Storage & Filter Unit Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2107 2107 Combustible Storage/Filter None None None None Unit Room Fire Area ID: 2-092 - Drumming Station & Storage & Combustible Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2420 2420 Drum Storage/Combustible None None None None Storage Room 2421 2421 Drumming None None None None Station/Combustible Storage Room Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 90 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-094 - Aux Building Combustible Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2167 2167 Combustible Storage Room None None None None Fire Area ID: 2-096 - Aux Building Combustible Storage Room Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2179 2179 Combustible Storage Room E E None Detection System, 2A-101: E Water Suppression, 2A-101A: E Fire Area ID: 2-097 - Filter Hatch Room & Combustible Storage Area Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2404 2404 Filter Hatch None None None None Room/Combustible Storage Area Fire Area ID: 2-098 - Caskwash Storage & Combustible Storage Area Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2447 2447 Caskwash Storage Area None None None None Combustible Storage Area Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 91 of 104

0 Attach~t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 2-DU-ABVB-A - Aux Building to Valve Box Ductbanks, Train A I Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-DU-ABVB-A Aux Building to Valve Box None None None None Ductbanks, Train A Fire Area ID: 2-DU-ABVB-B - Aux Building to Valve Box Ductbanks, Train B Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-DU-ABVB-B Aux Building to Valve Box None None None None Ductbanks, Train B Fire Area ID: 2-DU-DGRWIS-A - Diesel Building to RWIS Ductbank, Unit 2, Train A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-DU-DGRWIS-A Diesel Building to RWIS None None None None Ductbank, Unit 2, Train A Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 92 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-DU-DGRWIS-B - Diesel Building to RWIS Ductbank, Unit 2, Train B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-DU-DGRWIS-B Diesel Building to RWIS None None None None Ductbank, Unit 2, Train B Fire Area ID: 2-DU-DGSWIS-A - Diesel Building to SWIS Ductbank, Unit 2, Train A Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-DU-DGSWIS-A Diesel Building to SWIS None None None None Ductbank, Unit 2, Train A Fire Area ID: 2-DU-DGSWIS-B - Diesel Building to SWIS Ductbank, Unit 2, Train B Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-DU-DGSWIS-B Diesel Building to SWIS None None None None Ductbank, Unit 2, Train B Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 93 of 104 0

Attach tC Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: 2-EMBED-AB - Aux Building Embedded Conduit Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-EMBED-AB Embedded Conduit, Auxiliary None None None None Building, Unit 2 Fire Area ID: 2-SO1 - Stairwell No. 1 Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-SO1 Stairwell No. 1 None E, D E Detection System, 2A-110: E D Restricted transient controls: E Fire Area ID: 2-S02 - Stairwell No. 2 Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-S02 Stairwell No. 2 None E E, R, S Detection System, 2A-108: E Restricted transient controls: E Three Hour Rated

Enclosure:

R S Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 94 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-S08 - Stairwell No. 8 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-SO8 Stairwell No. 8 None None E Restricted transient controls: E Fire Area ID: 2-S10 - Stairwell No. 10 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-S10 Stairwell No. 10 None None E Restricted transient controls: E Fire Area ID: 2-SVB1-A - Service Water Valve Box, 2-SVB1, Train A Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-SVB1-A Service Water Valve Box, 2- None None None None SVB1, Train A Fire Area ID: 2-SVB1-B - Service Water Valve Box, 2-SVB1, Train B Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-SVB1-B Service Water Valve Box, 2- None None None None SVB1, Train B Fire Safety Analysis Data Manager (4.2) I Farley Run: 09/14/2012 08:11 Page: 95 of 104 s

0 Attachft C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-SVB2-A - Service Water Valve Box, 2-SVB2, Train A Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-SVB2-A Service Water Valve Box, 2- None None D Restricted transient controls: D SVB2, Train A Fire Area ID: 2-SVB2-B - Service Water Valve Box, 2-SVB2, Train B Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-SVB2-B Service Water Valve Box, 2- None None None None SVB2, Train B Fire Area ID: 2-SVB3-A - Service Water Valve Box, 2-SVB3, Train A Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-SVB3-A Service Water Valve Box, 2- None None None None SVB3, Train A Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 96 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-SVB3-B - Service Water Valve Box, 2-SVB3, Train B Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 2-SVB3-B Service Water Valve Box, 2- None None None None SVB3, Train B Fire Area ID: 2-SVB4-A - Service Water Valve Box, 2-SVB4, Train A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 2-SVB4-A Service Water Valve Box, 2- None None None None SVB4, Train A Fire Area ID: 2-SVB4-B - Service Water Valve Box, 2-SVB4, Train B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Drnforfinmnn i:flira Fire Zone ID Description S stem Protection Feature Required Fire Protection Feature and System Details stem 2-SVB4-B Service Water Valve Box, 2- None None None None SVB4, Train B Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 97 of 104

0 ~Attach~kt C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 2-TB - Turbine Building General Area Compliance Basis: Unit 2: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Unit 1: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Modifications: R 2-084 Turbine, SGFP, and H2 Seal Oil D D None Detection System, 2T-12A(D): D Conditioners & Reservoirs Detection System, 2T-12B(D): D Water Suppression, 2T-12A: D Water Suppression, 2T-12B: D Water Suppression, 2T-3: D Water Suppression, 2T-8: D Water Suppression, 2T-9: D 2-085 Turbine Building, General Area D D None Detection System, 2T-16A: D Detection System, 2T-16B: D Detection System, 2T-16C: D Detection System, 2T-16D: D Detection System, 2T-16E: D Detection System, 2T-20: D Water Suppression, 2T-10: D Water Suppression, 2T-121: D Water Suppression, 2T-16A: D Water Suppression, 2T-16B: D Water Suppression, 2T-16C: D Water Suppression, 2T-16D: D Water Suppression, 2T-16E: D Water Suppression, 2T-2: D Water Suppression, 2T-20: D Water Suppression, 2T-5A: D Water Suppression, 2T-5B: D Water Suppression, 2T-7A: D Water Suppression, 2T-7B: D Water Suppression, 2T-7C: D 2-0851 I - El. 189'-0", Entire Floor (less None None None None Zone H) and Platform at El. 207'- 0" 2-087 Steam Generator Feed Pumps A D D None Detection System, 2T-17: D

                       &B                                                                                                  Water Suppression, 2T-17: D 2-088                   Turbine Building Switchgear Area      R                   None                                      Gaseous Suppression, 2T-13: R None Gaseous Suppression, 2T-14: R Fire Safety Analysis Data Manager (4.2)                                                      Farley                                                      Run: 09/14/2012 08:11 Page: 98 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: ABRF-U1 - Control Room Air Conditioner, Unit 1 & Unit 2 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details ABRF1-U1 Control Room Air None None None None Conditioner/Unit 1 Side ABRF2-U1 Control Room Air None None None None Conditioner/Unit 2 Side Fire Area ID: ABRF-U2 - Control Room Air Conditioner, Unit 1 & Unit 2 Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details ABRF1-U2 Control Room Air None None None None Conditioner/Unit 1 Side ABRF2-U2 Control Room Air None None None None Conditioner/Unit 2 Side Fire Area ID: DU-DGFOST-A - Diesel Fuel Oil Storage Tank Ductbank, Train A Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DU-DGFOST-A Diesel Fuel Storage Tank None None None None Ductbank, Train A Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 99 of 104 0

Attach*t C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systemsand Features 0 Fire Area ID: DU-DGFOST-B - Diesel Fuel Oil Storage Tank Ductbank, Train B Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DU-DGFOST-B Diesel Fuel Storage Tank None None None None Ductbank, Train B Fire Area ID: DU-SWISVB-A-U1 - SWIS to Valve Box Ductbank, Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DU-SWISVB-A-U1 SWIS to Valve Box Ductbank, None None None None Train A Fire Area ID: DU-SWISVB-A-U2 - SWIS to Valve Box Ductbank, Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DU-SWISVB-A-U2 SWIS to Valve Box Ductbank, None None None None Train A Fire Area ID: DU-SWISVB-B-U1 - SWIS to Valve Box Ductbank, Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DU-SWISVB-B-U1 SWIS to Valve Box Ductbank, None None None None Train B Fire Safety Analysis Data Manager (4.2) Farley Run: 0911412012 08:11 Page: 100 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: DU-SWISVB-B-U2 - SWIS to Valve Box Ductbank, Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details DU-SWISVB-B-U2 SWIS to Valve Box Ductbank, None None None None Train B Fire Area ID: EMBED-DGB-U1 - Diesel Generator Building Embedded Conduit Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details EMBED-DGB-U1 Embedded Conduit, Diesel None None None None Generator Building Fire Area ID: EMBED-DGB-U2 - Diesel Generator Building Embedded Conduit Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details EMBED-DGB-U2 Embedded Conduit, Diesel None None None None Generator Building Fire Area ID: SWWPVB-A-U1 - Service Water Valve Box Return to Wet Pit, Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWWPVB-A-U1 Service Water Valve Box Return None None None None to Wet Pit, Train A Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 101 of 104 0

Attachft C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: SWWPVB-A-U2 - Service Water Valve Box Return to Wet Pit, Train A Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWWPVB-A-U2 Service Water Valve Box Return None None None None to Wet Pit, Train A Fire Area ID: SWWPVB-B-U1 - Service Water Valve Box Return to Wet Pit, Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWWPVB-B-U1 Service Water Valve Box Return None None None None to Wet Pit, Train B Fire Area ID: SWWPVB-B-U2 - Service Water Valve Box Return to Wet Pit, Train B Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details SWWPVB-B-U2 Service Water Valve Box Return None None None None to Wet Pit, Train B Fire Area ID: TBRF - Turbine Building Roof HVAC Room, Units 1 & 2 Compliance Basis: NFPA 805, Section 4.2.3 Deterministic Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details TBRF1 Turbine Building Roof HVAC None None E Heat activated Smoke Vents: E Room, Unit 1 TBRF2 Turbine Building Roof HVAC None None E Heat Activated Smoke Vents: E Room, Unit 2 Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 102 of 104

Attachment C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: YARD-SWIS-Ul - Yard Area in Vicinity of SWIS Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R C02-RM-U1 C02 Bottle Room (SWIS) None None None None SWIS-EXT-U1 SWIS Yard Area D None E Combustibles and flammable liquid control: E Hydrant, YARD-SWIS: D Fire Area ID: YARD-SWIS-U2 - Yard Area in Vicinity of SWIS Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R C02-RM-U2 C02 Bottle Room (SWIS) None None None None SWIS-EXT-U2 SWIS Yard Area None None E Combustibles and flammable liquid control: E Fire Area ID: YARD-Ul - Yard Area in Main Power Block Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-CST-PT-U 1 Access Hatch Room to CST Pipe None None None None Trench 1-SWSURTK-U1 Service Water Surge Tank None None D Restricted transient controls: D 2-CST-PT-U1 Aux Building to CST Pipe Trench None None None None 2-RWST-PT-U1 Aux Building to RWST Pipe None None None None Trench 2-SWSURTK-U1 Service Water Surge Tank None None None None FOST-Ul Fuel Oil Storage Tank None None None None HV-SWYD-U1 High Voltage Switchyard None None D Restricted transient controls: D OUTSIDE-U1 General Outside Locations in None None E Administrative Control of Vehicles: E Main Power Block Combustibles and flammable liquid control: E UNGND-U1 Underground Ductbanks None None D Restricted transient controls: D Between Various Structures Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 103 of 104 0 0

Attachlt C Table C-2, Table 4-3 NFPA 805 Required Fire Protection Systems and Features 0 Fire Area ID: YARD-U2 - Yard Area in Main Power Block Compliance Basis: NFPA 805, Section 4.2.4.2 Performance-Based Approach - Fire Risk Evatuation with simplifying deterministic assumptions Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 1-CST-PT-U2 Access Hatch Room to CST Pipe None None None None Trench 1-SWSURTK-U2 Service Water Surge Tank None None None None 2-CST-PT-U2 Aux Building to CST Pipe Trench None None None None 2-RWST-PT-U2 Aux Building to RWST Pipe None None None None Trench 2-SWSURTK-U2 Service Water Surge Tank None None None None FOST-U2 Fuel Oil Storage Tank None None None None HV-SWYD-U2 High Voltage Switchyard None None D Restricted transient controls: D OUTSIDE-U2 General Outside Locations in None None E Administrative Control of Vehicles: E Main Power Block Combustibles and flammable liquid control: E UNGND-U2 Underground Ductbanks None None None None Between Various Structures Fire Safety Analysis Data Manager (4.2) Farley Run: 09/14/2012 08:11 Page: 104 of 104

Southern Nuclear Operating Company Attachment D - Non-Power Operational Modes Transition D. NEI 04-02 Non-Power Operational Modes Transition 5 Pages Attached Attachment D is redacted in its entirety. Page D-1 01 Rev 01 Page D-1

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Southern Nuclear Operating Company Attachment E Radioactive Release Transition E. NEI 04-02 Radioactive Release Transition 23 Pages Attached Page E-1 Rev 01 Rev 01 Page E-1

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Compartment Identification - Auxiliary Building-RCA Compartment Selection and Justification Basis The Auxiliary Building includes unit specific and common locations. Many support systems are unit and area specific, but have similar design and ultimately support radioactive release in the same manner. As such, this compartment will address RCA areas of the Auxiliary Building for Units 1 and 2, including, but not limited to, the radwaste area, the fuel handling areas and access control area. Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan Pre-Fire Plan Description 051 Control Room HVAC Equipment Rooms N/A Plans will be developed 093 Aux Building 1-001 Aux Building 1-004 Aux Building 1-005 Aux Building 1-006 Aux Building 1-008 Aux Building Cable Chase, Room 116 1-009 Aux Building Cable Chase, Rooms 117 & 246 1-034 Train B Electrical Pen Room & Filtration System 1-035 Train A Electrical Pen Rooms 1-039 Fuel Storage & Storage Rack Pits 1-090 Aux Building Combustible Storage & Filter Unit Room 1-092 Drumming Station & Storage & Combustible Storage Room 1-094 Aux Building Combustible Storage Room 1-095 Aux Building Storage Room 1-096 Aux Building Combustible Storage Room 1-097 Filter Hatch Room & Combustible Storage Area 1-098 Cask Wash Storage & Combustible Storage Area 1-S02 Stairwell No. 2 1-S08 Stairwell No. 8 1-S10 Stairwell No. 10 Page E-2 Rev OkOk Page E-2 10 je

aern Nuclear Operating Company Attachment E - Radioactive Release Tation Release T*tion Attachment E Radioactive hem Nuclear Operating Company Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan I Pre-Fire Plan Description 2-001 Aux Building 2-004 Aux Building 2-005 Aux Building 2-006 Aux Building 2-008 Aux Building Cable Chase, Room 2116 2-009 Aux Building Calble Chase, Rooms 2117 & 2246 2-034 Train B Electrical Pen Room & Filtration System 2-035 Train A Electrical Pen Rooms 2-039 Fuel Storage & Storage Rack Pits 2-089 Lube Oil & Combustible Storage Room 2-090 Aux Building Combustible Storage & Filter Unit Room 2-092 Drumming Station & Storage & Combustible Storage Room 2-094 Waste Gas Decay Tank, Room 2167 2-096 Aux Building Combustible Storage Room 2-097 Filter Hatch Room & Combustible Storage Area 2-098 Cask Wash Storage & Combustible Storage Area 2-S02 Stairwell No. 2 2-S08 Stairwell No. 8 2-S10 Stairwell No. 10 Smoke and By-products of Combustion - Airborne Effluent Evaluation The Auxiliary Building is a hardened structure that provides a robust barrier between the RCA and the outside to minimize the likelihood of smoke being released without proper monitoring. Section 12.2 of the FSAR describes the ventilation system, related to radiation protection. FSAR Section 12.2.2 states that a negative pressure is maintained, where applicable, to prevent exfiltration of contamination. In addition, air movement patterns are designed to so as to move air from areas of lesser contamination to areas of greater contamination. High efficiency particulate air (HEPA) and charcoal filters are also provided to reduce or remove airborne activity. Rev Ok Page E-3

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition FSAR Section 9.4.2 provides a detailed description of the Auxiliary Building Ventilation System. Each unit is serviced by separate ventilation systems for the fuel handling area, the radwaste area, and the nonradioactive area. FSAR Section 12.4, Airborne Radioactivity Monitoring, outlines the methods used by FNP to maintain compliance with 10 CFR Part 20. The controls in place for day-to-day operation; surveys or continuous online type of sampling, clear identification of spaces with appropriate caution signs, locked doors with alarms as appropriate and administrative controls using radiation work permits and procedures, all support the radioactive release performance goal in the event of a fire. Two specific locations within the auxiliary building have special systems. First, the hood vents in the radiochemistry labs are exhausted to the radwaste area HVAC system. This is due to the high likelihood of contamination. The second is the Access Control Area. This location is complicated by the interface between the RCA and non-RCA with no physical barrier between the two. The ventilation system for this area is designed to move air from the clean area to the controlled or RCA portion of the area. Within the RCA, air is then moved as described above to reduce the potential spread of contamination. Booster fans area also located in this area to assist in the air movement from clean to controlled areas. Section 9B.2.2.4, Control of Radioactive or Hazardous Materials, states "Ventilation systems that could be used, if available, for smoke venting from radioactive areas discharge to the plant vent stack after passing air through filters to remove radioactive material." Fire Suppressant Runoff- Liquid Effluent Evaluation The Auxiliary Building is a hardened structure that provides a robust barrier between the RCA and the outside to minimize the likelihood of liquids, water from fire suppression activities, from being released without proper monitoring. FSAR Section 9.3.3, Equipment and Floor Drain System describes how the floor drains route to area sumps. These sumps are then pumped to the floor drain tank and the waste holdup tank. Each unit contains a 10,000-gallon floor drain tank. Once the liquid reaches the respective tank it enters the liquid waste processing system (LWPS). Nonradioactive areas of the Auxiliary Building have independent sumps that can manually transfer liquids to the turbine building sump. The LWPS is designed to collect and process potentially radioactive water originating within the auxiliary building. The LWPS is divided into Channel A and Channel B drain paths. The Channel B flow path includes floor drains, equipment drains and other non-reactor grade water source. The floor drain portion of this system includes a floor drain tank and a floor drain tank pump. FSAR Section 11.2.2.3, System Design (LWPS), provides details of the collection of floor drain water with the reactor plant to the floor drain tank. The floor drain tank pump can then pump the contents of the floor drain tank to the waste Rev Ok Page E-4 0 0s

Shern Nuclear Operating Company 9 Attachment E - Radioactive Release

  • tion monitor tank. The water, once in the waste holdup tank, is processed as ahy other radwaste within the system. Once processing is complete, the water may be reused or discharged based on the plant needs. FSAR Section 11.2.3.2 Instrumentation Design describes the monitoring in place to prevent a radioactive release from the LWPS.

Administrative Controls - Pre-fire Plans, Procedures, Guidelines to minimize the Risk of Radioactive Release Fire brigade response actions are provided in procedure FNP-0-EIP-13, Fire Emergencies. Steps in this procedure state that any fire within the RCA shall be considered to involve radioactive materials and monitoring by health physics shall be required (Step 3.2). Health physics responsibilities are listed in Step 4.1.6 of the procedure. Although implied, no clear step is listed to assist the fire brigade by monitoring of smoke or runoff to prevent an unmonitored radioactive release. Follow-up actions are provided in section 4.2.2 when the Dothan Fire Department responds. Again, radioactive release actions are implied but not clearly stated. Clear guidance will be added to section 4.1.6. Additional guidance is needed for the fire brigade and the Fire Brigade Chief. This guidance will prompt members for concerns for radioactive release and provide techniques for smoke scrubbing in the event of an exterior fire or a fire at a doorway or hatch to the outside. Fire Zone Data Sheets do not meet the requirement of the pre-fire plans. Modifications will be made to upgrade to pre-fire plans. These modifications will include identification, on the drawing or within the text portion of the pre-fire plan, of locations with a greater risk of radioactive release. These areas are RCA interface locations with doors and hatches. The site walk down identified the potential for smoke release in penetration areas where the seal between the containment structure and the penetration exist. Similar to doors and hatches, the seals will be noted as a point of vulnerability in the pre-fire plan for the area when created. Fire Brigade Training to Minimize Radioactive Release The Farley fire brigade training program includes a single slide that cautions against a release of radioactive material to the environment. No reference to water runoff is in place. Farley will follow the site and corporate training process to add a task to the "task list" contained in the Southern Nuclear Fire Training System Master Plan. This action will drive the creation of objectives and supporting training material be placed in the appropriate locations for the training program. Fire brigade personnel will be appropriately trained on the revised objectives to control radiological releases. Non-Power Operations Ventilation and drainage engineering controls are not affected by the unit operating condition. Plant operators that are assigned to the fire brigade are aware of changing plant conditions and are able to consider these conditions when a fire Rev Ok Page E-5

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition occurs. Administrative guidance, reinforced by training, will drive actions to prevent uncontrolled radioactive release in this scenario. Conclusion FNP uses three levels of defense to provide compliance. First, contain the source of the release by engineering or administrative controls. Second, have response personnel engaged and acting on the potential failure of the containment method. The last line of defense is provided by a radiation protection professional to support, monitor, and maintain compliance. With the identified enhancements to administrative controls, with re-enforcement through fire strategies, training, and the three levels of defense, FNP can provide reasonable assurance that fire suppression activities will not result in a radioactive release that exceeds the performance criteria of NFPA 805, 2001 edition. Rev Ok Page E-6 S0 0 0

.hern Nuclear Operating Company 0 Attachment E - Radioactive Release "jtion Compartment Identification - Reactor Containments Compartment Selection and Justification Basis Each of the two reactor containments are designed to contain airborne effluent and liquid effluent. The systems used for controlling the effluents are best described separate from the Auxiliary Building. Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan Pre-Fire Plan Description 1-055 Containment (Unit 1) N/A Plans will be developed 2-055 Containment (Unit 2) Smoke and By-products of Combustion - Airborne Effluent Evaluation The reactor containments have self-contained ventilation systems that recirculate air within the containment. The containment purge system is used to exhaust air from containment. This system is controlled manually. By design the containment is an air tight enclosure. Fire Suppressant Runoff- Liquid Effluent Evaluation The reactor containments are hardened structures that provide a robust barrier between the RCA and the outside to minimize the likelihood of liquids, water from fire suppression activities, from being released without proper monitoring. FSAR Section 9.3.3, Equipment and Floor Drain System describes how the floor drains route to area sumps. These sumps are then pumped to the floor drain tank and the waste holdup tank. Each unit contains a 10,000-gallon floor drain tank. Once the liquid reaches the respective tank it enters the liquid waste processing system (LWPS). The LWPS is designed to collect and process potentially radioactive water originating within the auxiliary building. The LWPS is divided into a Channel A and Channel B drain paths. The channel B flow path includes floor drains equipment drains and other nonreactor grade water source. The floor drain portion of this system includes a floor drain tank and a floor drain tank pump. FSAR Section 11.2.2.3, System Design (LWPS), provides details of the collection of floor drain water with the reactor plant to the floor drain tank. The floor drain tank pump can then pump the contents of the floor drain tank to the waste monitor tank. The water once in the waste holdup tank is processed as any other radwaste within the system. Once processing is complete, the water may be reused or discharged based on the plant needs. FSAR Section 11.2.3.2 Instrumentation Design describes the monitoring in place to prevent a radioactive release from the LWPS. Administrative Controls - Pre-fire Plans, Procedures, Guidelines to minimize the Risk of Radioactive Release Rev Ok Page E-7

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Fire brigade response actions are provided in procedure FNP-0-EIP-13, Fire Emergencies. Steps in this procedure state that any fire within the RCA shall be considered to involve radioactive materials and monitoring by health physics shall be required (Step 3.2). Health physics responsibilities are listed in Step 4.1.6 of the procedure. Although implied, no clear step is listed to assist the fire brigade by monitoring of smoke or runoff to prevent an unmonitored radioactive release. Follow-up actions are provided in section 4.2.2 when the Dothan Fire Department responds. Again, radioactive release actions are implied but not clearly stated. Clear guidance will be added to section 4.1.6. Additional guidance will be provided for the fire brigade and the Fire Brigade Chief. This guidance will prompt members for concerns for radioactive release and provide techniques for smoke scrubbing in the event of an exterior fire or a fire at a doorway or hatch to the outside. Fire Zone Data Sheets do not meet the requirement of the pre-fire plans. Modifications will be made to upgrade to pre-fire plans. These modification will include identification, on the drawing or within the text portion of the pre-fire plan, of locations with a greater risk of radioactive release. These areas are RCA interface locations with doors and hatches. Fire Brigade Training to Minimize Radioactive Release The Farley fire brigade training program includes a single slide that cautions against a release of radioactive material to the environment. No reference to water runoff is in place. Farley will follow the site and corporate training process to add a task to the "task list" contained in the Southern Nuclear Fire Training System Master Plan. This action will drive the creation of objectives and supporting training material be placed in the appropriate locations for the training program. Fire brigade personnel will be appropriately trained on the revised objectives to control radiological releases. Non-Power Operations Ventilation and drainage engineering controls are not affected by the unit operating condition. Plant operators that are assigned to the fire brigade are aware of changing plant conditions and are able to consider these conditions when a fire occurs. When condition do change, and during outage periods, administrative guidance, reinforced by training, will drive actions to prevent uncontrolled radioactive release in this scenario. Conclusion FNP uses three levels of defense to provide compliance. First, contain the source of the release by engineering or administrative controls. Second, have response personnel engaged and acting on the potential failure of the containment method. The last line of defense is provided by a radiation protection professional to support, monitor, and maintain compliance. U'* Rev Ok Page E-8

aern Nuclear Operating Company 0 Attachment E - Radioactive Release T tion With the identified enhancements to administrative controls, with re-enforcement through fire strategies, training, and the three levels of defense, FNP can provide reasonable assurance that fire suppression activities will not result in a radioactive release that exceeds the performance criteria of NFPA 805, 2001 edition. Page E-9 Ok Rev Ok Page E-9

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Compartment Identification - Low Level Radwaste Building Compartment Selection and Justification Basis The Low Level Radwaste Building (LLRB) compartment in located 350ft. northeast of the Unit 2 Containment. The compartment is confined to the building where a dry pipe sprinkler system and radiation monitors are installed. All remaining area near the Low Level Radwaste Building will be addressed by the compartment Yard-RCA. Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan Pre-Fire Plan Description YARD Yard Area in Main Power Block N/A I Plans will be developed No fire area designation was clear for the Low Level Radwaste Building. This structure is in scope for the radioactive release review. It has been assigned to YARD for this review. Smoke and By-products of Combustion - Airborne Effluent Evaluation The LLRB is equipped with exhaust fans to support general building ventilation. These fans are located in the roof of the building. An interlock between the fans and the radiation monitors will stop the fans if the set point is reached. Fire Suppressant Runoff - Liquid Effluent Evaluation The LLRB is designed to contain liquid effluent. The floor drains are routed to sump that will contain approximately 1,000 gallons of liquid. The sump contains installed pumps and piping to support manual transfer of liquids. By procedure, the sumps are monitored for radioactivity prior to transfer to the storm drain system. To support the increased flow rate of manual hose streams and/or multiple sprinklers activated, the foundation and floor are integrated to create a 8" berm from the base of the building. The LLRB is equipped with a dry pipe automatic sprinkler system. Water that escapes the building would drain into the yard. If the water makes it to the yard storm drain it would discharge to the river. No monitoring is located in the storm drain discharge. The East Yard Drain has the greatest risk of discharge based on the flow path near RCA areas. The South Yard drain has some risk limited to the area near the Unit 1 Containment equipment hatch. Administrative Controls - Pre-fire Plans, Procedures, Guidelines to minimize the Risk of Radioactive Release Fire brigade response actions are provided in procedure FNP-0-EIP-13, Fire Emergencies. Steps in this procedure state that any fire within the RCA shall be considered to involve radioactive materials and monitoring by health physics shall be required (Step 3.2). Rev Ok Page E-10 U 0 *

.hern Nuclear Operating Company 0 Attachment E - Radioactive Release T tion Health physics responsibilities are listed in Step 4.1.6 of the procedure. Although implied, no clear step is listed to assist the fire brigade by monitoring of smoke or runoff to prevent an unmonitored radioactive release. Follow-up actions are provided in section 4.2.2 when the Dothan Fire Department responds. Again, radioactive release actions are implied but not clearly stated. Clear guidance will be added to section 4.1.6. Additional guidance is needed for the fire brigade and the Fire Brigade Chief. This guidance will prompt members for concerns for radioactive release, provide techniques for smoke scrubbing in the event of an exterior fire or a fire at a doorway or hatch to the outside. Fire Zone Data Sheets do not meet the requirement of the pre-fire plans. Modifications will be made to upgrade to pre-fire plans. These modifications will include identification, on the drawing or within the text portion of the pre-fire plan, of locations with a greater risk of radioactive release. These areas are RCA interface locations with doors and hatches. A pre-fire plan will be created for the LLRB that includes specific concerns for water retention limits and airborne release potential. No fire zone datasheet was found for this structure. Fire Brigade Training to Minimize Radioactive Release The Farley fire brigade training program includes a single slide that cautions against'a release of radioactive material to the environment. No reference to water runoff is in place. Farley will follow the site and corporate training process to add a task to the "task list" contained in the Southern Nuclear Fire Training System Master Plan. This action will drive the creation of objectives and supporting training material be placed in the appropriate locations for the training program. Fire brigade personnel will be appropriately trained on the revised objectives to control radiological releases. Non-Power Operations Ventilation and drainage engineering controls are not affected by the unit operating condition. Plant operators that are assigned to the fire brigade are aware of changing plant conditions and are able to consider these conditions when a fire occurs. Administrative guidance, reinforced by training, will drive actions to prevent uncontrolled radioactive release in this scenario. Conclusion FNP uses three levels of defense to provide compliance. First, contain the source of the release by engineering or administrative controls. Second, have response personnel engaged and acting on the potential failure of the containment method. The last line of defense is provided by a radiation protection professional to support, monitor, and maintain compliance. Rev Ok Page E-1 1

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition With the identified enhancements to administrative controls, with re-enforcement through fire strategies, training, and the three levels of defense, FNP can provide reasonable assurance that fire suppression activities will not result in a radioactive release that exceeds the performance criteria of NFPA 805, 2001 edition. U Rev Ok Page E-12

ehern Nuclear Operating Company Attachment E - Radioactive Release Ttion Compartment Identification - Solidification/Dewatering Facility Compartment Selection and Justification Basis The Solidification/Dewatering Facility compartment in located in the yard between the Unit 1 and Unit 2 Refueling Water Storage Tanks, approximately 75 feet from the Unit 1 and Unit 2 Auxiliary Buildings. The compartment is confined to the building where a wet pipe sprinkler system is installed. All remaining area near the Solidification/Dewatering Facility will be addressed by the compartment Yard-RCA. Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan Pre-Fire Plan Description YARD Yard Area in Main Power Block N/A Plans will be developed No fire area designation was clear for the Solidification/Dewatering Facility. This structure is in scope for the radioactive release review. It has been assigned to YARD for this review. Smoke and By-products of Combustion - Airborne Effluent Evaluation The Solidification/Dewatering Facility contains three fans that discharge to areas within the building. Exhaust ventilation is natural flow from a series of louvered openings that discharge to atmosphere. Two of the three supply fans are located on an interior wall, taking a supply from the general area. Louvers in this area allow outside air to flow into the general room area. Each fan discharges into a separate area adjacent to the fan. The adjacent area has louvers in the exterior wall that allows natural flow to atmosphere. The third fan draws air directly from the exterior of the building and discharges into the Contaminated Oil, Paint and Scaffolding Storage Room. Air supply by this fan will discharge to atmosphere through louvers located in the exterior wall of the building. The Solidification/Dewatering Facility is provided with an automatic sprinkler system that can provide some level of smoke scrubbing as well as the designed fire protection function in the event of a fire. However, the vulnerability of the louvers should be added to the pre-fire plan for the building. Administrative controls will be used to meet NFPA 805 Radioactive Release requirements. Fire Suppressant Runoff- Liquid Effluent Evaluation The Solidification/Dewatering Facility is equipped with an automatic sprinkler system to reduce the likelihood of a major fire. The facility is designed to contain liquid effluent using the installed drains, sumps and berm created by the foundation. The sump contains installed pumps and piping support transfer of liquids to the plant LWPS, where effluent is monitored Rev Ok Page E-13

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition and process accordance with plant procedures. In addition to the installed drainage system, the foundation and floor are integrated to create a 6" berm from the base of the building. NFPA 805 Radioactive Release requirements will be met by the buildings engineering controls and re-enforced by supporting wording added to the pre-fire plans. Administrative Controls - Pre-fire Plans, Procedures, Guidelines to minimize the Risk of Radioactive Release Fire brigade response actions are provided in procedure FNP-0-EIP-13, Fire Emergencies. Steps in this procedure state that any fire within the RCA shall be considered to involve radioactive materials and monitoring by health physics shall be required (Step 3.2). Health physics responsibilities are listed in Step 4.1.6 of the procedure. Although implied, no clear step is listed to assist the fire brigade by monitoring of smoke or runoff to prevent an unmonitored radioactive release. Follow-up actions are provided in section 4.2.2 when the Dothan Fire Department responds. Again, radioactive release actions are implied but not clearly stated. Clear guidance will be added to section 4.1.6. Additional guidance is needed for the fire brigade and the Fire Brigade Chief. This guidance will prompt members for concerns for radioactive release, provide techniques for smoke scrubbing in the event of an exterior fire or fire at a doorway or hatch to the outside. Fire Zone Data Sheets do not meet the requirement of the pre-fire plans. Modifications will be made to upgrade to pre-fire plans. These modifications will include identification, on the drawing or within the text portion of the pre-fire plan, of location with a greater risk of radioactive release. These areas are RCA interface locations with doors and hatches. A pre-fire plan will be created for the Solidification/Dewatering Facility that includes specific concerns for water retention limits and airborne release potential. No fire zone datasheet was found for this structure. Fire Brigade Training to Minimize Radioactive Release The Farley fire brigade training program includes a single slide that cautions against a release of radioactive material to the environment. No reference to water runoff is in place. Farley will follow the site and corporate training process to add a task to the "task list" contained in the Southern Nuclear Fire Training System Master Plan. This action will drive the creation of objectives and supporting training material be placed in the appropriate locations for the training program. Fire brigade personnel will be appropriately trained on the revised objectives to control radiological releases. Non-Power Operations Ventilation and drainage engineering controls are not affected by the unit operating condition. Plant operators that are assigned to the fire brigade are aware of changing plant conditions and are able to consider these conditions when a fire S Rev Ok Page E-14

.hern Nuclear Operating Company Attachment E - Radioactive Release TA tion occurs. Administrative guidance, reinforced by training, will drive actions to prevent uncontrolled radioactive release in this scenario. Conclusion FNP uses three levels of defense to provide compliance. First, contain the source of the release by engineering or administrative controls. Second, have response personnel engaged and acting on the potential failure of the containment method. The last line of defense is provided by a radiation protection professional to support, monitor, and maintain compliance. With the identified enhancements to administrative controls, with re-enforcement through fire strategies, training, and the three levels of defense, FNP can provide reasonable assurance that fire suppression activities will not result in a radioactive release that exceeds the performance criteria of NFPA 805, 2001 edition. Page E-15 Ok Rev Ok Page E-15

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Compartment Identification - Yard Area-RCA Compartment Selection and Justification Basis The Yard-RCA compartment captures those locations that contain transient radioactive material or do not fall under a specific compartment. This also includes areas around the containment equipment hatch as well as the refueling water storage tanks. These areas are common to each other based on the need to use administrative controls to provide reasonable assurance that a radioactive release beyond 10 CFR Part 20 limits will not occur. Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan Pre-Fire Plan Description 1-077 Condensate Storage Tank N/A Plans will be developed 1-078 Reactor Makeup Storage Tank 1-079 Refueling Water Storage 2-077 Condensate Storage Tank 2-078 Reactor Makeup Storage Tank 2-079 Refueling Water Storage Tank YARD Yard Area in Main Power Block No fire area designation was clear for the Old Steam Generator Storage Structure. This structure is in scope for the radioactive release review. It has been assigned to YARD for this review. Smoke and By-products of Combustion - Airborne Effluent Evaluation No engineering controls are available outside of the buildings to contain or control the release of smoke in the event of a fire. Administrative controls will be used to ensure compliance with NFPA 805 Radioactive Release requirements. Fire Suppressant Runoff - Liquid Effluent Evaluation The yard area is provided with storm drains that discharge to the river. No monitoring is located in the storm drain discharge. The East Yard Drain has the greatest risk of for discharge based on the flow path near RCA areas. The South Yard drain has some risk limited to the area near the Unit 1 Containment equipment hatch. Administrative Controls- - Pre-fire Plans, Procedures, Guidelines to minimize the Risk of Radioactive Release Fire brigade response actions are provided in procedure FNP-0-EIP-13, Fire Emergencies. Steps in this procedure state that any fire within the RCA shall be considered to involve radioactive materials and monitoring by health physics shall be required (Step 3.2). S'* Rev Ok Page E-16

.hern Nuclear Operating Company S Attachment E - Radioactive Release Tltion Health physics responsibilities are listed in Step 4.1.6 of the procedure. Although implied, no clear step is listed to assist the fire brigade by monitoring of smoke or runoff to prevent an unmonitored radioactive release. Follow-up actions are provided in section 4.2.2 when the Dothan Fire Department responds. Again, radioactive release actions are implied but not clearly stated. Clear guidance will be added to section 4.1.6. Additional guidance is needed for the fire brigade and the Fire Brigade Chief. This guidance will prompt members for concerns for radioactive release, provide techniques for smoke scrubbing in the event of an exterior fire or a fire at a doorway or hatch to the outside. Fire Zone Data Sheets do not meet the requirement of the pre-fire plans. Modifications will be made to upgrade to pre-fire plans. These modifications will include identification, on the drawing or within the text portion of the pre-fire plan, of locations with a greater risk of radioactive release. These areas are RCA interface locations with doors and hatches. A pre-fire plan will be created for the Old Steam Generator Storage Structure. No fire zone datasheet was found for this structure. Fire Brigade Training to Minimize Radioactive Release The Farley fire brigade training program includes a single slide that cautions against a release of radioactive material to the environment. No reference to water runoff is in place. Farley will follow the site and corporate training process to add a task to the "task list" contained in the Southern Nuclear Fire Training System Master Plan. This action will drive the creation of objectives and supporting training material be placed in the appropriate locations for the training program. Fire brigade personnel will be appropriately trained on the revised objectives to control radiological releases. Non-Power Operations Yard area RCA locations are not affected by the plant operating condition. No change in the methods of controlling and preventing radioactive release will take place during non-power operations. Conclusion FNP uses three levels of defense to provide compliance. First, contain the source of the release by engineering or administrative controls. Second, have response personnel engaged and acting on the potential failure of the containment method. The last line of defense is provided by a radiation protection professional to support, monitor, and maintain compliance. With the identified enhancements to administrative controls, with re-enforcement through fire strategies, training, and the three levels of defense, FNP can provide reasonable assurance that fire suppression activities will not result in a radioactive release that exceeds the performance criteria of NFPA 805, 2001 edition. Rev Ok Page E-17

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Compartment Identification - Non-RCA Compartment Selection and Justification Basis The Non-RCA Areas compartment consists of those Fire Area/Fire Zones that are not part of the radiologically controlled area of the unit. These areas do not store or contain radioactive material that could result in the potential for a radioactive release. Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan Pre-Fire Plan Description 044 Control Room Complex & TSC N/A Plans will be developed 056A DG Building Switchgear Room Train A 056B DG Building Switchgear Room Train B & Foyer 057 Diesel Generator Room 2C 058 Diesel Generator Room 1B 059 Diesel Generator Room 2B 060 Diesel Generator Room 1C 061 Diesel Generator Room 1-2A 062 Day Fuel Tank Room 2C 063 Day Fuel Tank Room 1B 064 Day Fuel Tank Room 2B 065 Day Fuel Tank Room 1C 066 Day Fuel Tank Room 1-2A 067 RWIS Pump Room B 068 RWIS Pump Room A 069 RWIS Switchgear Room-Train B 070 RWIS Switchgear Room-Train A 071 DG Building Corridor 072 Service Water Pump Room 073 SWIS Battery Room-Train B 074 SWIS Battery Room-Train A 075 SWIS 5 kV Switchgear Room B & West Stairs Page E-18 Rev OkOk Page E-18 1 0

Ohern Nuclear Operating Company . Attachment E - Radioactive Release Tation Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan I Pre-Fire Plan Description 076 SWIS 5 kV Switchgear Room A & East Stairs 1-012 Hallway & Local Hot Shutdown Panel Room Aux Building Cable Chase, Rooms 227, 300, 465, 466, & 500 1-014 Computer Room & Duct Chase 1-015 Communication Room 1-016 Aux Building Battery Room 1-017 Aux Building Battery Room 1-018 Aux Building DC Switchgear Room 1-019 Aux Building DC Switchgear Room 1-020 Aux Building 1-021 Aux Building Switchgear Rooms 1-023 Aux Building Switchgear Room 1-030 Aux Building Cable Chase, Rooms 249 & 252 1-031 Aux Building Cable Chase, Rooms 250 & 251 1-040 Cable Spreading Room 1-041 Train A Switchgear & Load Center Rooms 1-042 Aux Building Hallways & Corridor Aux Building Elevator Machine Room No.1 and Elevator No.1 Shaft 1-075 Unit 1 Cable Tunnel- Train A 1-076 Unit 1 Cable Tunnel - Train B 1-080 Low Voltage Switchyard - Unit 1 1-081 Turbine Building Battery Room 1-082 Turbine Building Lube Oil Storage Room 1-083 Turbine Building Oil Storage Room 1-086 Turbine Building Auxiliary Steam Generator 1-DU-DRWS-A Diesel Building to RWIS Ductbank, Unit 1, Train A DGRWIS-A 1-DU- Diesel Building to RWIS Ductbank, Unit 1 Train B Page E-19 Rev Ok Rev Ok Page E-19

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Southern Nuclear Operating Company Attachment E Radioactive Release Transition Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan I Pre-Fire Plan Description DGRWIS-B 1-DU-

  -DG I-A    Diesel Building to SWIS Ductbank, Unit 1, Train A DGSWlS-A 1-DU-DGWS-B      Diesel Building to SWIS Ductbank, Unit 1, Train B DGSWIS-B 1-DU-DGVB-A      Diesel Building To Valve Box Ductbanks, Train A DGVB-A 1-DU-DGVB-B      Diesel Building To Valve Box Ductbanks, Train B DGVB-B 1-EMBED-     Aux Building Embedded Conduit AB 1-S01        Stairwell No. 1 1-SVB1-A     Service Water Valve Box, 1-SVB1, Train A 1-SVB1-B     Service Water Valve Box, 1-SVB1, Train B 1-SVB2-A     Service Water Valve Box, 1-SVB2, Train A 1-SVB2-B     Service Water Valve Box, 1-SVB2, Train B 1-SVB3-A     Service Water Valve Box, 1-SVB3, Train A 1-SVB3-B     Service Water Valve Box, 1-SVB3, Train B 1-SVB4-A     Service Water Valve Box, 1-SVB4, Train A 1-SVB4-B     Service Water Valve Box, 1-SVB4, Train B 1-TB         Turbine Building General Area 2-012        Hallway & Local Hot Shutdown Panel Room Aux Building Cable Chase, Rooms 2227, 2300, 2466,
             & 2500 2-014        Computer Room 2-015        Communication Room 2-016        Aux Building Battery Room 2-017        Aux Building Battery Room 2-018        Aux Building DC Switchgear Room 2-019        Aux Building DC Switchgear Room 2-020        Aux Building Rev Ok                                                                                                           Page E-20 40,                                                             0                                               0

Shern Nuclear Operating Company 0 Attachment E - Radioactive Release *tion 0 Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan I Pre-Fire Plan Description 2-021 Aux Building Switchgear Rooms 2-023 Aux Building Switchgear Room 2-030 Aux Building Cable Chase, Rooms 2249 &2252 2-031 Aux Building Cable Chase, Rooms 2250 & 2251 2-040 Cable Spreading Room 2-041 Train A Switchgear & Load Center Rooms 2-042 Aux Building Hallways & Corridor 2-043 Aux Building Aux Building Elevator Machine Room No. 4 and Elevator No. 1 Shaft 2-075 Unit 2 Cable Tunnel- Train A 2-076 Unit 2 Cable Tunnel -Train B 2-080 Low Voltage Switchyard- Unit 2 2-081 Turbine Building Battery Room 2-DU-ABVB- Aux Building to Valve Ductbanks, Train A A 2-DU-ABVB- Aux Building to Valve Ductbanks, Train B B 2-DU-

  -DGR-A    Diesel Building to RWIS Ductbank, Unit 2 Train A DGRWIS-A 2-DU-DGRW-B     Diesel Building to RWIS Ductbank, Unit 2 Train B DGRWlS-B 2-DU-
  -DGWS     Diesel Building to SWIS Ductbank, Unit 2 Train A DGSWlS-A 2-DU-DGSS-B     Diesel Building to SWIS Ductbank, Unit 2 Train B DGSWIS-B 2-EMBED-    Aux Building Embedded Conduit AB 2-SO1       Stairwell No. 1 2-SVB1-A    Service Water Valve Box, 2-SVB1, Train A 2-SVB1-B    Service Water Valve Box, 2-SVB1, Train B 2-SVB2-A    Service Water Valve Box, 2-SVB2, Train A Page E-21 Ok Rev Ok                                                                                                        Page E-21

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Southern Nuclear Operating Company Attachment E Radioactive Release Transition Related Fire Areas Related Pre-Fire Plans Fire Area Fire Area Description Pre-Fire Plan I Pre-Fire Plan Description 2-SVB2-B Service Water Valve Box, 2-SVB2, Train B 2-SVB3-A Service Water Valve Box, 2-SVB3, Train A 2-SVB3-B Service Water Valve Box, 2-SVB3, Train B 2-SVB4-A Service Water Valve Box, 2-SVB4, Train A 2-SVB4-B Service Water Valve Box, 2-SVB4, Train B 2-TB Turbine Building General Area ABRF Control Room Air Conditioner, Unit 1 & Unit 2 DU-DGFROST- Diesel Fuel Oil Storage Tank Ductbank, Train A A DU-DGFROST- Diesel Fuel Oil Storage Tank Ductbank, Train B B DU-D V-A SWIS to Valve Box Ductbank, Train A SWlSVB-A DU-D V-B SWIS to Valve Box Ductbank, Train B SWlSVB-B EMBED- Diesel Generator Building Embedded Conduit DGB SWWPVB-A Service Water Valve Box Return to Wet Pit, Train A SWWPVB-B Service Water Valve Box Return to Wet Pit, Train B TBRF Turbine Building Roof HVAC Room , Units 1 & 2 YARD Yard Area in Main Power Block YRD-SWIS Yard Area in Vicinity of SWIS Smoke and By-products of Combustion - Airborne Effluent Evaluation Non-RCA - Screens out of Radioactive Release Review. Fire Suppressant Runoff - Liquid Effluent Evaluation Non-RCA - Screens out of Radioactive Release Review. Administrative Controls - Pre-fire Plans, Procedures, Guidelines to minimize the Risk of Radioactive Release Non-RCA - Screens out of Radioactive Release Review. Rev Ok Pa-ge E-22 SI 0

Wern Nuclear Operating Company Attachment E - Radioactive Release 411tion 4 Fire hem Nuclear Brigade Operating Company Training to Minimize Radioactive Release Non-RCA - Screens out of Radioactive Release Review. Attachment E - Radioactive Release tion Non-Power Operations Non-RCA - Screens out of Radioactive Release Review. Conclusion Non-RCA - Screens out of Radioactive Release Review. Page E-23 Ok Rev Ok Page E-23

Southern Nuclear Operating Company Attachment E - Radioactive Release Transition Compartment Identification - ISFSI Related Fire Areas None - No fire area designation is assigned to this area as part of the FNP 805 transition, nor is there required to be. See Compartment Selection and Justification Basis for an explanation of why this is not required. Compartment Selection and Justification Basis ISFSI is outside of the scope of NFPA 805 and this review. 10 CFR 72.122 establishes the criteria for "protection against fires and explosions". ISFSI has been included within this document to show each fire area and/or area with radioactive materials was considered during the Radioactive Release Evaluation. Smoke and By-products of Combustion - Airborne Effluent Evaluation ISFSI is outside of the scope of NFPA 805. Fire Suppressant Runoff- Liquid Effluent Evaluation ISFSI is outside of the scope of NFPA 805. Administrative Controls - Pre-fire Plans, Procedures, Guidelines to minimize the Risk of Radioactive Release ISFSI is outside of the scope of NFPA 805. Fire Brigade Training to Minimize Radioactive Release ISFSI is outside of the scope of NFPA 805. Non-Power Operations ISFSI is outside of the scope of NFPA 805. Conclusion ISFSI is outside of the scope of NFPA 805. Rev Ok Page E-24

Southern Nuclear Operating Company Attachment F - Fire-Induced IVISOs Resolution F. Fire-Induced Multiple Spurious Operations Resolution 5 Pages Attached Page F-I Rev 01 01 Page F-1

Southern Nuclear Operating Company Attachment F - Fire-induced MSOs Resolution MSO Process Summary The following provides the guidance from FAQ 07-0038, Revision 3, along with the process and results. Step 1 - Identify potential MSOs of concern Information sources that may be used as input include:

   " Post-fire safe shutdown analysis (NEI 00-01, Revision 1, Chapter 3)
   " Generic lists of MSOs (e.g., from Owners Groups and/or later versions of NEI 00-01, if endorsed by NRC for use in assessing MSOs)
  • Self-assessment results (e.g., NEI 04-06 assessments performed to addressed RIS 2004-03)
  • PRA insights (e.g., NEI 00-01 Revision 1, Appendix F)
  • Operating Experience (e.g., licensee event reports, NRC Inspection Findings, etc.)

Results of Step 1: The following information sources were used to identify the potential FNP MSOs of concern:

   " Piping and Instrumentation Diagrams (P & IDs)
   " Procedures
   " Safe Shutdown Analysis
   " Training diagrams
   " Fire PRA insights
   " Internal Events P]]